# Regulatory Impact Analysis for

Conditional Exclusions from

Solid Waste and Hazardous Waste

f

or Solvent

- Contaminated Wipes

Final Rule

Office of Resource Conservation and Recovery
U.S. Environmental Protection Agency

June 21, 2013

# Ac knowledgements

This document was prepared by the U.S. Environmental Protection Agency (EPA’s) Office of Resource Conservation and Recovery (ORCR) wi th support from ICF International under EPA

Contract EP

- W

- 10

- 056, Task Order 0043.

### i 

# Table of Contents

Executive Summary

................................ ................................ ................................ ................................ .... 1

ES.1 Introduction

................................ ................................ ................................ ................................ .. 1

ES.2 Characteriz ation of Generators and Handlers of Solvent

- Contaminated Wipes

........................ 1

ES.3 Existing Regulatory Environment and the Affected Universe

................................ ..................... 2

ES.4 Estimated Costs and Savings of the Final Rule

................................ ................................ .......... 3

ES.5 Other Expected Benefits of the Final Rule

................................ ................................ .................. 4

ES.6 Comparison of Benefits to Costs

................................ ................................ ................................ . 5

1. Introduction

................................ ................................ ................................ ................................ ........... 9

1.1. Need for Regulatory Action

................................ ................................ ................................ ......... 9

1.2. Summary of Current Regulations

................................ ................................ ................................ 9

1.3. Summary of Regulatory Changes in Final Rule

................................ ................................ ........ 10

1.3.1. Solvent

- Contaminated Reusable Wipes

................................ ................................ ...... 12

1.3.2. Solvent

- Contaminated Disposable Wipes

................................ ................................ .... 12

1.4. Alternatives Considered by EPA

................................ ................................ ............................... 13

1.4.1. Modifications to Conditions for RCRA Exclusions

................................ ....................... 13

1.4.1.1. Conditions for Initial Storag e and Accumulation

................................ ............. 13

1.4.1.2. Conditions for Containers Used for Transportation

................................ ........ 14

1.4.1.3. Labeling Condition f or Containers Used To Transport

Solvent

- Contaminated Wipes

................................ ................................ ......... 15

1.4.1.4. Condition for Transportation to Laundry, Dry Cleaner, or Handler

................. 16

1.4.1.5. Condition for Transpo rtation to a Municipal or Other

Non

- Hazardous Landfill

................................ ................................ ................... 16

1.4.1.6. Condition for Transportation to Non

- Land Disposal Facilities

......................... 17

1.4.1.7. Conditions for Intra

- Company Transfers

................................ ......................... 17

1.4.2. Exclusion from the Definition of Ha zardous Waste for R eusable and

Solvent

- Contaminated Disposable Wipes

................................ ................................ .... 18

1.4.3. Exclusion from the Definition of Haz ardous Waste for All Disposable

Solvent

- Contaminated Wipes under a Single Set of Conditions

................................ .. 19

2. Characterization of Generators and Handlers of Solvent

- Contaminated Wipes

......................... 20

2.1. Industries That Generate or Handle Solvent

- Contaminated Wipes

................................ .......... 22

2.2. Generation of Solvent

- Contaminated Wipes

................................ ................................ ............. 26

2.2.1. Number of Generators of Solvent

- Contaminated Wipes

................................ ............. 26

2.2.2. Annual Number of Solvent

- Contaminated Wipes

................................ ........................ 30

# Table of Contents (continued)

ii 2.3. Handling of Solvent

- Contaminated Wipes

................................ ................................ ................ 33

2.3.1. Number of Handlers of Solvent

- Contaminated Reusable Wipes

................................ . 33

2.3.2. Number of Handlers of Solvent

- Contaminated Disposable Wipes

.............................. 33

3. Existing Regulatory Environment and the Affected Universe

................................ ....................... 34

3.1. Existing Regulations Applicable to Solvent

- Contaminated Wipes

................................ ............ 34

3.1.1. Federal Regulations Applicabl e to Generators and Handlers of

Solvent

- Contaminated Wipes

................................ ................................ ....................... 34

3.1.2. State Policies Applicabl e to Generators and Handlers of

Solvent

- Contaminated Wipes

................................ ................................ ....................... 35

3.1.2.1. State Policies on Solvent

- Contaminated Reusable Wipes

............................. 35

3.1.2.2. State Policies on Solvent

- Contaminated Disposable Wipes

........................... 36

3.2. Regulatory Baseline

................................ ................................ ................................ .................. 36

4. Estim ated Costs and Savings of the Final Rule

................................ ................................ .............. 41

4.1. Summary of Costs and Savings

................................ ................................ ................................ 41

4.2. Costs and Savings by Type of Facility

................................ ................................ ...................... 42

4.3. Derivation of Cost and Savings Elements

................................ ................................ ................. 48

4.3.1. Reading the Final Rule

................................ ................................ ................................ . 49

4.3.2. Familiarizing Employees with the Final Rule Requirements and
Implementation Procedures/Practices

................................ ................................ ......... 50

4.3.3. Purchase of Containers

................................ ................................ ................................ 51

4.3.4. Purchase of Labels

................................ ................................ ................................ ...... 54

4.3.5. Affixing Labels to Containers

................................ ................................ ....................... 55

4.3.6. Removing “Free Liquids” from Containers

................................ ................................ ... 56

4.3.7. Management of “Free Liquids” Removed Containers

................................ .................. 58

4.3.8. Avoided Hazardous Waste Manifest Costs

................................ ................................ .. 59

4.3.9. Avoided Disposal Costs

................................ ................................ ............................... 61

4.3.10. Complying with Recordkeeping Requirements under the Final Rule

.......................... 66

4.3.11. Demonstrating Compli ance with Final Rule Conditions

................................ ............... 67

4.3.12. Avoided RCRA Information Collec tion Requirement Costs for SQGs
that May Become CESQGs

................................ ................................ ......................... 69

4.3.13. Avoided State Waste Fees and Taxes

................................ ................................ ......... 70

# Table of Contents (continued)

iii 5. Other Expected Benefits of the Final Rule

................................ ................................ ....................... 73

5.1. Summary of Other Expected Benefits

................................ ................................ ....................... 73

5.2. Expected Pollution Prevention and Waste Minimization Benefits

................................ ............. 74

5.3. Expected Fire Safety Benefits

................................ ................................ ................................ ... 76

5.4. Expected Benefits to Industrial Laundries from Excluding Solvent

- Contaminated Reusable
Wipes from the Definition of Solid Waste

................................ ................................ .................. 78

6. Comparison of Benefits to Costs

................................ ................................ ................................ ...... 81

6.1. Net Benefits of the Final Rule

................................ ................................ ................................ ... 81

6.2. Sensitivity Analysis

................................ ................................ ................................ .................... 82

7. Sup plemental Analyses Required by Congre ssional Statutes or White House

Executive Orders

................................ ................................ ................................ ................................ 85

7.1. Regulatory Flexibility Act (RFA), a s Amended by the Small Business
Regulatory Enforcement Fairness Act (SBREFA)

................................ ................................ .... 85

7.2. Executive Order 12630: Regulatory Takings Analys is

................................ ............................. 97

7.3. Executive Order 12988: Civil Justice Reform

................................ ................................ .......... 97

7.4. Executive Order 12898: Federal Actions t o Address Environmental Justice
in Minority Populations and Low

- Income Populations

................................ .............................. 97

7.5. Executive Order 13045: Protection of Children from Environmental Health Risks
and Safety Risks

................................ ................................ ................................ ....................... 99

7.6. Unfunded Mandate Reform Act (UMRA)

................................ ................................ .................. 99

7.7. Executive Order 13132: Federalism

................................ ................................ ...................... 101

7.8. Executive Order 13175: Consultation and Coordination with Indian Tribal Governments

.... 101

7.9. Executive Order 13211: Actions That Sign ificantly Affect Energy Supply,

Distribution, or Use

................................ ................................ ................................ .................. 102

7.10. Executive Order 13352: Facilitation of Cooperative Conservation

................................ ........ 102



## Appendices

Appendix A Description of North American Industry Classification System (NAICS) Codes Associated with Industries that May Be Affected by the Final Rule

Appendix B Information on State Waste Fees and Taxes

Appendix C Number of Facilities that Generate Solvent

- Contaminated Wipes, by Industry

### iv [Page intentionally left blank.]

### 1 

# Executive Summary

ES.1 Introduction

This regulatory impact analysis (RIA) analyzes the economic effect s of the U.S. Environmental Protection Agency’s (EPA’s) final rule on the conditional exclusion s of solvent

- contaminated wipes from the Resource Conservation and Recovery Act (RCRA) hazardous waste regulations.

EPA is modifying its hazardous waste management regulations to:

• Conditionally exclude from the definition of solid waste wipes that are con taminated with

hazardous solvents and are sent to an industrial laundry or to a dry cleaner for cleaning

and reuse (hereinafter referred to as “solvent

- contaminated reusable wipes ” ) ; and

• Conditionally exclude from the definition of hazardous waste wipes that are

contaminated with hazardous solvents and are sent for disposal to a landfill or

combust or (hereinafter referred to as “solvent

- contaminated disposable wipes ” )

.

The conditional exclusions will apply to wipes that, after use or after cleaning up a spill, either: (1) contain one or more of the F001 through F005 solvent s listed in 40 CFR 261.31 or the corresponding P

- or U

- listed solvents found in 40 CFR 261.33; (2) exhibit a hazardous characteristic found in 40 CFR Part 261, Subpart C when that characteristic results from a solvent listed in 40 CFR Part 261; and/or (3) exhibit only the hazardous waste characteristic of ignitability found in 40 CFR 261.21 due to the presence of one or more solvents that are not

listed in 40 CFR Part 261. Solvent

- contaminated wipes that contain listed hazardous waste

other than solvents or exhibit t he characteristic of toxicity, corrosivity, or reactivity due to contaminants other than solvents are not eligible for the exclusions at 40 CFR 261.4(a)(26) and 40 CFR 261.4(b)(18).

The final rule will clarify the existing Federal hazardous waste requirem ents associated with

solvent

- contaminated wipes and provide regulatory relief as long as certain conditions are met. EPA’s current policy with respect to the regulatory status of solvent

- contaminated wipes is to

defer the determination of whether solvent

- contaminated wipes must be managed as a solid or hazardous waste to the EPA Regional Offices and s tate agencies. However, c urrent rules and policies at the EPA Regional Office

- and state

- level are inconsistent. Furthermore, EPA has

determined that wipes can be managed appropriately with the less restrictive regulation established in this rulemaking, while maintaining protection of human health and the

environment.



# ES.2 Characterization of Generators and Handlers of Solvent

Contaminated Wipes

E ntities that may be affected by the final rule include the following (Chapter 2 of this document describes them in more detail):

• Generators of solvent

- contaminated wipes

. These include f acilities that use reusable

and/or disposable wipes in conjunction with hazardous solvents. EPA identified 113 industries (based on five

- or six

- digit North American Industry Classification System

### 2 

## (NAICS) codes 1 

## ) with facilities that generate solvent

- contaminated wipes and, therefore, may be affected by the final rule (see Exhibit 2

- 2 in Chapter 2). In particular, EPA

estimates that , each year, 90,549 facilities generate solvent

- contaminated wipes. This estimate includes 576 large quantity generators (LQGs) 2 

## and 89,973 small quantity generators (SQGs) 3 

## . Collectively, these LQGs and SQGs generate 2.2 billion solvent

contaminated wipes each year (see Section 2.2)

. Conditionally exempt small quantity
generators (CESQ G s) are not affected by the final rule. 4



## • Handlers of solvent

- contaminated wipes. Thes e include industrial laundries and dry

cleaners that clean solvent

- contaminated reusable wipes , and solid waste management facilities that manag e solvent

- contaminated disposable wipes once they have been discarded (i.e., hazardous and non

- hazardous landfil ls/combustors). EPA identified eight industries (based on five

- or six

- digit NAICS codes ) with facilities that handle

solvent

- contaminated wipes and, therefore, may be affected by the final rule (see Exhibit

2

- 2 in Chapter 2). In particular, EPA estimates that , each year, 4,089 facilities handle

solvent

- contaminated wipes. This estimate includes 359 industrial laundries and dry

cleaners , and 3,730 solid waste management facilities (see Section 2.3).



# ES.3 Existing Regulatory Environment and the Affe cted Universe

As noted above, EPA’s existing policy on solvent

- contaminated wipes has led to the application

of different regulatory schemes for solvent

- contaminated wipes across the country. T he anticipated impact of the final rule will vary by s tate , d epending on whether they have existing

state policies addressing solvent

- contaminated wipes

. (See Chapter 3 for further discussion.)

The regulatory baseline used in this RIA is as follows: 5



## • Twenty

- five percent of facilities will not be affected by the final rule, either because they

are located in s tates that have exclusions similar to the exclusions included in this final rule, or because they are located in states that currently have no conditional exclusions

for solvent

- contaminated wipes . These states are expected to decide not to adopt

EPA’s final rule.

1 

### NAICS is the standard used by Federal statistical agencies in classifying business establishments for the purpose of collecting, analyzing, and publishing statistical data related to the U.S. business economy.

2 

### LQGs are facilities that generate 1,000 kilograms (2,200 pounds or 1. 10 tons) or more of hazardous waste in any single calendar month, or more than 1 kilogram (2.2 pounds or 0.001 ton) of acute hazardous waste in any single calendar month, or more than 100 kilograms (220 pounds or 0.11 ton) of acute hazardous waste spill cl ean

- up material in any single calendar month.

3 

### S QGs are facilities that generate between 100 kilograms (220 pounds or 0.11 ton) and 1,000 kilograms (2,200 pounds or 1.10 tons) of hazardous waste in any single calendar month.

4 

### CES QGs are facilitie s that generate 100 kilograms (220 pounds or 0.11 ton) or less of hazardous waste in any single calendar month, or 1 kilogram (2.2 pounds or 0.001 ton) or less of acute hazardous waste in any single calendar month, or 100 kilograms (220 pounds or 0.11 ton) or less of acute hazardous waste spill clean

- up material in any single calendar month. CESQGs are exempt from 40 CFR Parts 262 through 270 if they comply with the requirements at 40 CFR 261.5.

5 

### These assumptions are consistent with the assumptions unde r the “State Policy Baseline” in the economic background document originally developed for the proposed rule. U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p.53.

### 3 

## • Seventy

- five percent of facilities will be affected by the final rule because they are
located in states that have conditional exclusions for solvent

- contamin ated wipes

different from the exclusions in the final rule. These states are expected to adopt EPA’s

final rule.

Based on the above rationale, this analysis assumes that 75 percent of the LQGs and SQGs that generate solvent

- contaminated wipes are located in states that are expected to adopt the final rule, and consequently these LQGs and SQGs will incur incremental costs or savings as a result of the final rule. All wipes generated by these LQGs and SQGs will enter the non

hazardous waste stream. T o simplify the analysis, states that have conditional exclusions all

are assumed to have similar conditions for their exclusions. These conditions require laundering and reuse of the solvent

- contaminated wipes, and that the wipes contain “no free liqui ds.”



# ES.4 Estimated Costs and Savings of the Final Rule

EPA estimates that the total one

- time cost of the final rule across all facilities is approximately $1.2 million in the first

- year after promulgation of the final rule. EPA also estimates total annual

costs of approximately $ 6.3 million and total annual savings of approximately $ 24.4 million across all affected entities. EPA evaluated these costs and savings over a 10

- year period. 6


## (See Chapter 4 for further discussion of costs and savings.)

For purposes of this RIA , one

- time costs include:

• Reading the final rule.

Annual costs include:

• Becoming familiar with the final rule requirements and implementation procedures/practices.

• Purchase of containers.

• Purchase of labels.

• Affixing labels to containers.

• Removing "free liquids" from containers.

• Recordkeeping requirements under the final rule.

• Demonstrating compliance with final rule requirements.

Annual savings include:

• Management of “free liquids” removed from containers.

• Avoided hazardous w aste manifest costs.

• Avoided disposal costs.

• Avoided RCRA information collection requirement costs to SQGs that may become

CESQGs.

6 

### Under the final rule, the only one

- time cost element is reading the regulations. All other cost and savings elements are estimated on an annual basis. The analysis evaluates costs and savings over a 10

- year period in order to avoid understating the impacts associated with the one

- time costs.

### 4 

## • Avoided s tate waste fees and taxes.

As summarized in Exhibit ES

- 1, EPA estimates that the final rule will result in annual n et savings of approximately $1 8.0 million (2011 dollars), at each of the three real discount rates used in the analysis (i.e., 7 percent, 3 percent, and 0 percent).

Exhibit ES

- 1

Annual Economic Impacts of the Final Rule , 2011 Dollars a

Type s of Impact 7%

Discount Rate 3%

Discount Rate 0%

Discount Rate

Annualized One

- Time Cost $163,630 $139,961 $122,971

Annual Costs b $6,261,270 $6,261,270 $6,261,270

Annual Savings $24,375,585 $24,375,585 $24,375,585

Net Savings c $17,950,686 $17,974,354 $17,991,344

a Costs and savings are evaluated over a 10

- year period.

b Annual costs do not include annualized one

- time costs.

c Net savings = [Annual Savings]

– ( [On e

- Time Costs] + [Annual Costs]).



# ES.5 Other Expected Benefits of the Final Rule

The primary benefit of the final rule is the annual savings associated with avoided RCRA regulatory compliance. However, EPA also expects that the final rule will res ult in other expected benefits: (1) pollution prevention and waste minimization benefits, (2) fire safety benefits, and (3) p otential benefits to industrial laundries by excluding solvent

- contaminated

reusable wipes from the definition of solid waste

— that is, removing the “wa ste” label

.

Exhibit ES

- 2 summarizes the annual values for these other expected benefits of the final rule, which are further discussed in Chapter 5. As shown in the exhibit, at all three discount rates (i.e., 7 percent, 3 percent, and 0 percent), the o ther expected benefits of the final rule are

estimated a t between $ 3.7 million and $ 9.9 million per year (2011 dollars).

### 5 

## Exhibit ES

- 2

Other Annual Expected Benefits of the Final Rule , 2011 Dollars a , b



### ( A t All Three Discount Rates Used in the Analysis)

Type s of Impact Benefits (2011 Dollars)

Annual Pollution Prevention and Waste Minimization Benefits $212,358 to $960,593

Annual Fire Safety Benefits $230

, 922 to $ 2,309, 219

Annual Benefits to Industrial Laundries by excluding solvent

- contaminated reusable wipes from the definition of solid waste $3,293,366 to $6,586,733

Total Other Annual Expected Benefits c $3,736,647 to $ 9,856, 546

a O ther expected benefits are evaluated over a 10

- year period

.

b Because the value of the expected benefits is the same for each year under evaluation, the annual benefits are the same at al l three discount rates used in the analysis.

c Total Other Expected Benefits = [ Annual Pollution Prevention and Waste Minimiz ation Benefits ] + [Annual Fire Safety Benefits ] + [Annual Benefits to Industrial Laundries by excluding solvent

- contaminated reusable wipes from the definition of solid waste ].



# ES.6 Comparison of Benefits to Costs

Exhibit ES

- 3 presents the annual estimates for the costs and benefits of the final rule. As shown in the exhibit, the annual net benefits of the final rule are estimated at between $ 21.7 million and $ 27.8 million, regardless of discount rate (2011 dollars). Therefore, EPA can certify

that the fin al rule is not a n “ economic ally significant regulatory action” under Section 3(f)(1) of Executive Order 12866 (Regulatory Planning and Review). 7

7 

### Under Section 3(f)(1) of Executive Order 12866, Regulatory Planning and Review, a "significant regulatory action" means any regulator y action that is likely to result in a rule that may have an annual effect on the economy of $100 million or more or adversely affect in a material way the economy, a sector of the economy, productivity, competition, jobs, the environment, public health or safety, or state, local, or tribal governments or communities.

### 6 

## Exhibit ES

- 3 Comparison of Benefits to Costs under the Final Rule, 2011 Dollars a

Type s of Impact 7% 3% 0%

Discount Rate Discount Rate Discount Rate

Benefits

Annual Regulatory Compliance Savings (i.e., avoided costs) $24,375,585 $24,375,585 $24,375,585

Other Annual Expected Benefits $3,736,647 to $9,856, 5 46 $3,736,647 to $9,856, 5 46 $3,736,647 to $9,856, 5 46

Total Benefits $28, 112

, 232 to $ 34

, 232

, 1 31 $28,112,232 to $ 34

, 232

, 131 $28,112,232 to $ 34

, 232

, 131

Costs

Annual Regulatory Compliance Costs b $6,424,899 $6,401,231 $6,384,241

Total Costs $6,424,899 $6,401,231 $6,384,241

Net Benefits

Net Benefits c $ 21,687,333 to $ 27,807, 231 $ 21,711,001 to $ 27

, 830

, 900 $ 21

, 727,991 to $ 27

, 847

, 890

a C osts and benefits are evaluated over a 10

- year period.

b Annual regulatory compliance costs include annualized one

- time costs as well as annual costs.

c Net Benefits = [Total Benefits]

- [Total Costs].



## EPA also conducted a sensitivity analysis in order to determine whether, and to what extent, the results of the analysis are sensitive to changes in key assumptions and numeric inputs ( s ee Section 6.2 for further discussion of the sensitivity analysis.) The sensitivity analysis estimates economic impacts according to the three alternative sets of parameter s shown in Exhibit 6

- 2 :

Exhibit ES

- 4 Assumptions Associated with Key Parameters Used

in Sensitivity Analysis of Economic Impact Estimation

Cost Element Lower

Bound Most Likely Upper

Bound

Affected

Universe Percent of s tates that will adopt the final rule 50% 75% 100%

Containers

for Solvent

Contaminated Wipes Percent of wipes not currently accumulated, stored, and transported in closed containers 25% 50% 80%

Management of "Free Liquids" Percent of solvent

- contaminated wipes with "free liquids" Printers 90% 100% 100%

Non

- Printers 40 % 50 % 60%



## The results of the sensitivity analysis are reflected in the following Office of Management and Budget (OMB) A

- 4 Accounting Statement.

### 7 

## OMB A

- 4 ACCOUNTING STATEMENT
(2011 $Millions)

OMB #: [ Insert No. 

## ] Agency/Program Office: EPA/Office of Resource Co nservation and Recovery

Rule Title : Conditional Exclusions from Solid Waste and Hazardous Waste for Solvent

- Contaminated

Wipes

RIN#: [ Insert No. 

## ] Date: [ Insert Date 

## ]

Category Primary

Estimate Minimum

Estimate Maximum

Estimate Source Citation
(RIA, Preamble, etc.)

BENEFITS

Monetized Benefits $2 8.1 to $ 34.2 $ 19.8 to $ 24.9 $ 36.4 to $ 43.5 RIA

Annualized quantified, but non monetized, benefits None N/A N/A RIA

Unquantified Benefits None N/A N/A RIA

COSTS

Annualized monetized costs
(discount rate in parenthesis) a 

### $ 6.4 (7%) $ 4

.2 (7%) $ 8.8 (7%)

RIA $

6.4 (3%) $ 4

.2 (3%) $ 8.8 (3%)

$

6.4 (0%) $ 4

.2 (0%) $ 8.7 (0%)

Annualized quantified, but non monetized, costs None N/A N/A RIA

Qualitative (unquantified) costs None N/A N/A RIA

TRANSFERS

Annualized monetized transfers: “on budget” None N/A N/A RIA

Annualized monetized transfers: “off

- budget” None N/A N/A RIA

MISCELLANEOUS ANALYSES

Effects on State, local, and/or tribal governments None RIA

Effects on small businesses None RIA

Effects on wages None RIA

Effects on growth None RIA

### 8 [Page intentionally left blank.]

### 9 

# 1. Introduction

This RIA analyzes the economic effect s of EPA’s final rule on the c onditional exclusions of

s olvent

- c ontaminated w ipes from the RCRA h azardous w aste r egulation s

. EPA is modifying its hazardous waste management regulations under RCRA for certain solvent

- contaminated materials, such as shop towels, rags, pad, and swabs (hereinafter referred to as “wipes”)

. The affected universe for this final rule encompasses wipes that facilities use to clean surfaces, parts, accessories, and equipment in conjunction with solvents that when spent are hazardous wastes. Once wipes are used and are no longer suitable for thei r intended purpose, they

become solid wastes and may need to be managed as hazardous wastes, depending upon the

kind of solvent used with the wipes. EPA’s concern surrounding the use of wipes is based on the hazardous solvent contained in the used wipes, not the wipes themselves. Many solvents used by industry can pose unacceptable risks to human health and the environment if improperly managed

. EPA estimates that , each year, 90,549 facilities generate 2.2 billion

solvent

- contaminated wipes, and that 4,0 89 facilities handle these wipes.



## 1.1. Need for Regulatory Action

The final rule will clarify existing Federal hazardous waste requirements associated with solvent

contaminated wipes and provide regulatory relief as long as certain conditions are met

. EPA’s current policy with respect to the regulatory status of solvent

- contaminated wipes is to defer the

determination of whether solvent

- contaminated wipes must be managed as a solid or hazardous waste to the EPA Regional Offices and s tate agencies. Howe ver, c urrent rules and policies at the EPA Regional Office

- and state

- level are inconsistent. Furthermore, EPA has determined

that wipes can be managed appropriately with less restrictive regulation while maintaining protection of human health and the environment

.

EPA’s intent in promulgating the final rule is to resolve, at the Federal level, long

- standing issues associated with the management of solvent

- contaminated wipes by providing consistency in the regulations governing solvent

- contaminated wi pes across the U.S

. This rule maintains protection of human health and the environment, while creating flexibility and reducing compliance costs for generators of solvent

- contaminated wipes.



## 1.2. Summary of Current Regulations

Under the F ederal RCRA program, solvent

- contaminated wipes meet the definition of

hazardous waste if they :

• E xhibit one or more of the characteristics of hazardous waste identified in 40 CFR

Part 261, Subpart C;

• A re listed as a hazardous waste under 40 CFR Part 261, Subpart D ; 8



## • Are a mixture of a solid waste and a hazardous wa ste that is listed in 40 CFR Part 261,

S ubpart D; or

8 

### Under the Federal RCRA regulations, wipes contaminated with listed hazardous waste solvents (i.e., EPA

ha zardous waste codes F001

- F005) are considered to be listed hazardous wastes

.

### 10 

## • Are a mixture of a solid waste and a characteristic hazardous waste, and the resultant

mixture exhibits one or more hazardous waste charact eristic s

.

However, i t has long been EPA’s policy to defer the determination of whether solvent

contaminated wipes must be managed as a solid or hazardous waste to the EPA Regional

Offices and s tate agencies due to case

- specific circumstances (e.g., type o f solvent used, degree of hazard, when a spent solvent is generated, and whether the hazardous waste mixture rule applies to a particular waste ).

T he majority of the s tates have developed their own policies governing the management of

solvent

- contaminated wipes. However, a few s tates have deferred regulatory decisions regarding the management of solvent

- contaminated wipes to their respective EPA Regional

O ffices. Thus, EPA’s policy on solvent

- contaminated wipes led to the application of different regulatory schemes for solvent

- contaminated wipes across the country

.



## 1.3. Summary of Regulatory Changes in Final Rule

EPA is modifying its hazardous waste management regulations under RCRA to:

• Solvent

- Contaminated Reusable Wipes. Conditionally exclude from the definition of

solid waste wipes that are contaminated with hazardous solvents and are sent to an industrial laundry or to a dry cleaner for cleaning and reuse (hereinafter referred to as

“ solvent

- contaminated reusable wipes ” ) ; and

• Solvent

- Contaminated Disposable Wip es. Conditionally exclude from the definition of hazardous waste wipes that are contaminated with hazardous solvents and are sent for disposal to a landfill or combustor (hereinafter referred to as “solvent

- cont aminated disposable wipes”)

.

The conditional exclusion s will apply to wipes that, after use or after cleaning up a spill, either: (1) contain one or more of the F001 through F005 solvents listed in 40 CFR 261.31 or the corresponding P

- or U

- listed solven ts found in 40 CFR 261.33; (2) exhibit a hazardous characteristic found in 40 CFR Part 261, Subpart C when that characteristic results from a solvent listed in 40 CFR Part 261; and/or (3) exhibit only the hazardous waste characteristic of ignitability foun d in 40 CFR 261.21 due to the presence of one or more solvents that are not

listed in 40 CFR Part 261. Solvent

- contaminated wipes that contain listed hazardous waste other than solvents or exhibit the characteristic of toxicity, corrosivity, or reactivity due to contaminants other than solvents are not eligible for the exclusions at 40 CFR 261.4(a)(26) and 40 CFR 261.4(b)(18). Exhibit 1

- 1 identifies the Federal hazardous waste codes associated with

solvent

- contaminated wipes.

The exclusion s are applicable only when specified conditions are met. These conditions are briefly discussed in the following sections

.

### 11 

## Exhibit 1

- 1

Federal Hazardous Waste Codes Associated with Solvent

- Contaminated Wipes

Federal

Waste Code s Federal Waste Code Descri ption s

Characteristic or D

- Listed Wastes. A “characteristic waste” is any solid waste that exhibits one or more of the following characteristics: ignitability, corrosivity, reactivity, or toxicity. Additional information about each of the hazardous waste characteristics may be reviewed at 40 CFR 261.21 through 261.24.

D001 Ignitable waste.

F

- Listed Wastes. This list, at 40 CFR 261.31, includes wastes from certain common manufacturing and industrial processes. Because they are not specific to one type of industry, they are called wastes from non

- specific sources.

F001 The following spent halogenated solvents used in degreasing: tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1

- trichloroethane, carbon tetrachloride, and chlorinated fluorocarbons; all spent solvent mixtures/blends used in degreasing containing, before use, a total of ten percent or more (by volume) of one or more of the above halogenated solvents or those solvents listed in F002, F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures.

F002 The following spent halogenated solvents: tetrachloroethylene, methylene chloride, trichloroethylene,
1,1,1 trichloroethane, chlorobenzene, 1,1,2

- trichloro

- 1,2,2

- trifluoroethane, ortho

- dichlorobenzene, trichlorofluoromethane, and 1,1,2

- trichloroethane; all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above halogenated solvents or those listed in F001, F004, or F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures.

F002 The following spent non

- halogenated solvents: Xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, n

- butyl alcohol, cyclohexanone, and methanol; all spent solvent mixtures/blends containing, before use, only the above spent non

- halogenated solvents; and all spent solvent mixtures/blends containing, before u se, one or more of the above non

- halogenated solvents, and, a total of ten percent or more (by volume) of one or more of those solvents listed in F001, F002, F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixt ures.

F004 The following spent non

- halogenated solvents: Cresols and cresylic acid, and nitrobenzene; all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above

non

- halogenated solvents or those solvents listed in F001, F002, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures.

F005 The following spent non

- halogenated solvents: Toluene, methyl ethyl ketone, carbon disulfide, isobutanol, pyrid ine, benzene, 2

- ethoxyethanol, and 2

- nitropropane; all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above non

- halogenated solvents or those
solvents listed in F001, F002, or F004; an d still bottoms from the recovery of these spent solvents and spent

solvent mixtures.

P

- and U

- Listed Wastes. These two lists, at 40 CFR 261.33, designate certain commercial chemical products as hazardous when disposed of unused. The primary difference be tween P

- listed and U

- listed wastes is that, when discarded, P

- listed wastes are considered “acutely hazardous,” while U

- listed wastes are considered "hazardous." Thus, U

- listed wastes are regulated in a somewhat less stringent manner than P

- listed wastes.

P022 Carbon disulfide.

U019 Benzene.

U037 Chlorobenzene.

U052 Cresol (Cresylic acid).

U070 o

- Dichlorobenzene

U080 Methylene chloride.

U159 Methyl ethyl ketone (MEK).

U169 Nitrobenzene.

U171 2

- Nitropropane.

U196 Pyridine.

U210 Tetrachloroethylene

. U211 Carbon tetrachloride.

U220 Toluene.

U226 1,1,1

- Trichloroethane.

U227 1,1,2

- Trichloroethane.

U228 Trichloroethylene.

### 12 

## 1.3.1. Solvent

- Contaminated Reusable Wipes

For solvent

- contaminated reusable wipes to be eligible for the exclusion from the definition of
solid waste, they must : (1) be accumulate d

, store d , and transport ed in non

- leaking, closed

containers 9 

## that are labeled “Ex cluded Solvent

- Contaminated Wipes;” (2) be accumulate d by the generator for no more than 180 days from the start date of accumulation for each container prior to being sent for cleaning ; and (3) contain “no free liquids ” at the point of being sent for cleaning on

- site or at the point of being transported off

- site for cleaning as determined by the

Paint Filter Liquids Test (EPA Methods Test 9095B). Free liquids removed from the solvent

contaminated wipes or from the container holding the wipes must be managed according to the applicable regulations found in 40 CFR Parts 260 through 273

. Generators must maintain at

their site documentation that they are managing the solvent

- contaminated wipes under the conditional exclusion, including documentation on where the wipes are being sent for cleaning

, how they are meeting the 180

- day accumulation time limit, a nd how they are meeting the “no free liquids” standard.

S olvent

- contaminated reusable wipes must be sent to an industrial laundry or dry cleaner whose discharge , if any, is regulated under Section s 301 and 402 or Section 307 of the Clean Water

Act (e.g., National Pollutant Discharge Elimination System (NPDES) , discharge to a publicly owned treatment work ( POTW) )

.



## 1.3.2. Solvent

- Contaminated Disposable Wipes

For solvent

- contaminated disposable wipes to be eligible for the conditional exclusion from the definition of hazardous waste, they must not be hazardous for trichloroethylene. In addition, the

solvent

- contaminated disposable wipes must: (1) be accumulated, stored, and transported in

non

- l eaking, closed containers 10 

## that are labeled “Excluded Solvent

- Contaminated Wipes;” (2)

be accumulated by the generator for no more than 180 days from the start date of accumulation

for each container prior to being sent for disposal; and (3) contain “no free liquids” at the point of being transported for disposal as determined by the Paint Filter Liquids Test (EPA Methods Test 9095B) . Free liquids removed from the solvent

- contaminated wipes or from th e container holding the wipes must be managed according to the applicable regulations found in 40 CFR Parts 260 through 273. Generators must maintain at their site documentation that they are managing the solvent

- contaminated wipes under the conditional e xclusion, including documentation on where the wipes are being sent for disposal, how they are meeting the 180

- day accumulation time limit, and how they are meeting the “no free liquids” standard.

Solvent

- contaminated disposable wipes may be sent for disp osal to a municipal solid waste

landfill regulated under 40 CFR Part 258, including 40 CFR 258.40, or to a hazardous waste

landfill regulated under 40 CFR Part 264 or 265. In addition, solvent

- contaminated disposable wipes may be sent for disposal to a mu nicipal solid waste combustor or other combustion facility regulated under Section 129 of the Clean Air Act, or to a hazardous waste combustor , boiler, or

industrial furnace regulated under 40 CFR Part 264 ; 265 ; or 266, Subpart H

.

9 

### The containers must be able to contain free liquids, should free liquids occur. During accumulation, a container is considered closed when there is complete contact between the fitted lid and the rim, except when it is necessary to add or remove solvent

- conta minated wipes. When the container is full, or when the solvent

contaminated wipes are no longer being accumulated, or when the container is being transported, the container must be sealed with all lids properly and securely affixed to the container and al l openings tightly bound or closed sufficiently to prevent leaks and emissions.

10 

### Ibid.

### 13 

## 1.4. Alternatives Conside red by EPA

EPA s elected the final regulatory approach after considering several alternative options and approaches, including alternatives that are both more and l ess stringent than the final regula tory action. In the following paragraphs, EPA briefly summarizes its evaluation of the alternatives considered as part of this final rulemaking effort. 11



## 1.4.1. Modifications to Conditions for RCRA Exclusion s

This section briefly describes the alternative options considered and evaluated by EPA in establishing co nditions for the exclusion from the regulatory definition of solid waste for reusable wipes and the e xclusion from the regulatory definition of hazardous waste for disposable wipes

. For each of the conditions, EPA presents the proposed condition and the c orresponding alternative option(s). 12

, 13



## 1.4.1.1. C onditions for Initial Storage and Accumulation

Propos ed Rule

In the 2003 proposed rule, EPA included a condition for the on

- site accumulation and storage of

solvent

- contaminated wipes that would require the use of non

- leaking, covered containers.

Generators would be required to accumulate and store solvent

- contaminated wipes in covered

containers that do not allow solvent to b e released from the container. The container must not leak liquids and must protect against fugitive air releases of solvents when not in use. As part of
this condition, there would be no time limit for accumulation of solvent

- contaminated wipes

, if

the specified type of container is used

.

Alternative Option

- Accumulation Time Limit

In the preamble to the proposed rule, EPA indicated that it was consider ing including a condition

that would establish a time limit for accumulation of solvent

- contaminated disposable wipes at a generator facility, so they could not be kept on site indefinitely without management. As part of

this c ondition

, solvent

- contaminated disposable wipes being accumulated at the generator

, under the specified conditions

, would also have to follow the accumulation time limits in 40 CFR

262.34 : 90 days for lar ge quantity generators (LQGs) and 180 days for small quantity generators (SQGs). In addition to the accumulation time limits, generators would have to mark any container in which solvent

- contaminated disposable wipes were being accumulated with a

label stating that it holds excluded wipes and the date accumulation started.

Based on comments received on the proposed rule and further analysis conducted by EPA

, EPA decided to include a 180

- day accumulation time limit condition for both reusable and

11 

### This document only analyzes the option chosen for the final rule in detail and the analysis starts in Chapter 2.

12 

### U.S. Government Printing Office. Federal Regist er

. “ Hazardous Waste Management System: Identification and Listing of Hazardous Waste: Conditional Exclusions From Hazardous Waste and Solid Waste for

Solvent

- Contaminated Industrial Wipes. ” 68 FR 65586. November 20, 2003.

13 

### This section does not present a description of all conditions proposed in 2003. It only describes those
conditions for which EPA considered and evaluated for the final rulemaking stage.

### 14 

## disposa ble wipes. This condition ensures that free liquids are removed from the wipes and the container within a specified time frame and thus cannot be stored indefinitely in lieu of being disposed or laundered

.

Alternative Option

- No RCRA

- Specific Condition

In the preamble to the proposed rule, EPA also indicated that it was consider ing not to establish a specific accumulation condition, but relying on other regulatory statutes, such as the Occupational Safety and Health Act. The Occupational Safety and He alth Administration’s ( OSHA’s ) occupational health an d safety standards, specified in 29 CFR P art 1910, provide both general and specific requirements for containers used to accumulate and store certain types of materials. Subpart H of P art 1910 may be applicable for the storage of wipes prior to solvent removal or recovery. Section 1910.106 contains standards for the management of
hazardous materials, including requirements for the management of flammable 14 

## and combustible liquids 15 

## ; facilities which ei ther generate or launder solvent

- contaminated wipes may be subject to these standards. Section 1910.106 also specifies standards for the areas where containers holding flammable liquids are to be kept. In addition, s torage of solvent

contaminated wipes th at contain a negligible amount of solvents may be addressed under

OSHA’s regulations at 29 CFR 1910.106(e)(9)(iii), which describe general housekeeping

measures for ‘‘combustible waste material and residues’’ and residues of flammable liquids,

combustible waste material

, and residues in a building or unit operating area.

Based on further analysis, EPA determined that the OSHA regulations may not cover every workplace covered by the RCRA regulations . As a result, there might be gaps in regulatory

coverage if EPA relied strictly on deferring to OSHA regulations. For example, the OSHA

container standards may not apply to solvent

- contaminated wipes with no free

- flowing liquids or

when wipes are contaminated with non

- flammable solvents. Additionally, state and local government workers are excluded from federal coverage under OSHA

. Therefore, EPA decided

not to pursue this alternative option

.

Alternative Option

- Closed Containers

Based on comments received on the proposed rule and further analysis conducted by EPA

, EPA decided to require the use of non

- leaking, closed containers for the initial storage and

accumulation of solvent

- contaminated wipes. EPA determined that w ipes managed in closed

containers that are able to contai n liquids reduce the risk of adverse impacts to human health and the environment resulting from release of solvents.



## 1.4.1.2. Conditions for Containers Used for Transportation

Propos ed Rule

In the 2003 proposed rule, EPA included a container condition for generators who transport

solvent

- contaminated wipes off

- site under the conditional exclusion s

. This condition would

14 

### Flammable liquids are defined as any liquid having a flash point below 100° F (37.8° C) or higher, the total of which make up 99 percent or more of the total volume of the mixture. Several solvents that are either listed or characteristic hazardous wastes and are used in conjunction with wipes also meet the definition of a flammable liquid (s uch as acetone, ethyl acetate, ethyl benzene, methyl ethyl ketone, petroleum naphtha).

15 

### Combustible liquids are any liquids having a flash point at or above 100° F (37.8° C).

### 15 

## ensure that transporting the wipes without full RCRA ha zardous waste requirements would still
protect against risks posed by these material s to human health and the environment. Under the proposal, generators must transport wipes in containers that are designed, c onstructed and managed to minimize loss to the environment. In proposi ng this condition, EPA envisioned

containers that do not le ak liquids and that provide for control of air emissions. EPA would consider hazardous solvents that are spilled or leaked during transportation to be disposed. Therefore, the party managing the wipes at the time the spill occurred would be responsible for cleaning up the spill and managing those materials appropriately.

Alternative Option

- Closed Containers

In the preamble to the proposed rule, EPA indicated that it was consider ing an alternative option of requiring all generators of solvent

- contamin ated wipes to transport them in impermeable

closed containers. By closed containers, EPA specifically mean t containers with a lid that screws on to the top and must be sealed to be considered closed.

Based on comments received on the proposed rule and further analysis conducted by EPA

, EPA decided to require the use of non

- leaking, closed containers for the transport of solvent

contaminated wipes. EPA determined that w ipes managed in closed containers that are able to contain liquids reduce the risk of adverse impacts to human health and the environment resulting from release of solvents.



## 1.4.1.3. Labeling Condition for Containers Used To Transport Solvent

Contaminated Wipes

Propos ed Rule

In the 2003 proposed rule, EPA included a labeling requirement that would require the use of specific language or a pre

- made label, such as “Excluded Solvent

- Contaminated Wipes,” to be applied to each container used to accumulate and/or store solvent

- conta minated wipes, unless the wipes are being recycled.

Alternative Option

- No RCRA

- Specific Labeling Condition

In the preamble to the proposed rule, EPA indicated that it was consider ing not to impos e a specific labeling condition. Under this alternative option

, designation of the disposable wipes as

hazardous materials under the U.S. Department of Transportation ( DOT ) regulations might still require placarding or other marking for transportation of some fraction of these materials.
However, EPA did not expect that the DOT provisions would apply to all solvent

- contaminated wipes covered by the rule.

Based on comments received on the proposed rule and further analysis conducted by EPA

, EPA determined that the labeling requirement is necessary in order to al low identification of

container contents by emergency response personnel, motor carrier inspectors, downstream
transporters

, and handlers. Therefore, EPA decided not to include this condition in the final

rule.

### 16 

## 1.4.1.4. Condition for Transportation to Laundry, Dry Cleaner, or Handler

Propos ed Rule

In the 2003 proposed rule, EPA required generators meet the ‘‘no free liquids’’ condition prior to

solvent

- contaminated reusable wipes being transported off

- site to be cleaned for re

- use or being

laundered on site.

Alternative Option

– “No Free Liquids when Wrung”

In the preamble to the proposed rule, EPA indicated that it was considering a ‘‘no free liquids when wrung’’ condition

, instead of the ‘‘no free liquids’’ condition. This approach differs from the proposed approach in that it would require that each wipe could not drip solvent when hand

wrung.

Based on comments received on the proposed rule and further analysis conducted by EPA, EPA decided not to include the “no free liquids when wrung” condition in the final rule because it carries the perception of increased worker exposure due to hand wringing. Additional ly, this standard is subjective because of the variability associated with the people doing the wringing.



## 1.4.1.5. Condition for Transportation to a Municipal or Other Non

- Hazardous

Landfill

Propos ed Rule

In the 2003 proposed rule, EPA included two conditions for allowing generators to transport

certain solvent

- contaminated disposable wipes to municipal or other non

- hazardous waste

landfills that meet the standards under 40 CFR Part 257, Subpart B, when the conditions of the

exclusion are met. These conditions include: (1) the wipes must meet the “dry” condition (i.e.,

contain no more than five grams of solvent) and (2) the wipes must not be cont aminated with any of 11 solvents identified by EPA

.

Alternative Option

– “No Free Liquids”

Based on comments received on the proposed rule and further analysis conducted by EPA

, EPA considered and evaluated the “no free liquids” standard as a condition for the

t ransportation of solvent

- contaminated wipes to a l andfill

. For purposes of the final rule, E PA

define s “no free liquids” in terms of the EPA Methods Test 9095B

- Paint Filter Liquids Test.

EPA decided to include this condition in the final rule because this s tandard is currently used by

many s tates

. Moreover, the 40 CFR Part 258 municipal waste landfill regulations have liquid restrictions that also use the language “no free liquids.” Therefore, the “no free liquids” standard

should be relative ly familiar to the regulated industry and easy to implement

.

Alternative Option

– List of Solvents Not Allowed in Non

- Hazardous Waste Landfills

Based on comments received on the risk screening analysis conducted for the proposed rule,

EPA conducted a risk analysis in 2009 for resid ual solvents on disposable wipes. This risk analysis uses updated science and assumptions that reflect curr ent waste management practices. In finalizing the rule, EPA decided to defer to the re sults of the 2009 risk analysi s and

allow toxicity characteristic ( TC ) s olvents that pass the wipes risk assessment to be eligible for

### 17 

## the hazardous waste exclusion for disposable wipes, even when the TC level is exceeded. As a
result, trichloroethylene will be the only solvent not al lowed in non

- hazardous waste landfills,

based on the fact that it exceeds the risk threshold

.

Alternative Option

– Specify Type of Non

- Hazardous Waste Landfill

The 2009 risk analysis evaluated disposal in lined landfills and disposal in unlined landfills. Based on the results of the risk analysis, EPA considered three non

- hazardous waste landfill options in finalizing the rule: (1) allow disposal of solvent

- con taminated wipes only in a municipal solid waste landfill that meets 40 CFR Part 258 standards, (2) allow disposal of

solvent

- contaminated wipes in 40 CFR Part 257 non

- hazardous waste landfills that have composite liners, and (3) allow disposal of solvent

- c ontaminated wipes that do not exceed the risk criteria for an unlined landfill to go to 40 CFR Part 257 non

- hazardous waste landfills without liners. After carefully reviewing each option, EPA decided to allow disposal of solvent

contaminated wipes only i n a municipal solid waste landfill that meets Part 258 standards (i.e., Option 1). EPA determined that this option is protective of human health and the

environment for all scenarios evaluated in the risk analysis , can be implemented through

normal munic ipal waste service contracts, and eliminates t he need for the generator (and s tate enforcement) to independently verify that the correct type of wipes are being sent to the appropriate type of landfills.



## 1.4.1.6. Condition for Transportation to Non

- Land Disposal Facilities

Propos ed Rule

In the 2003 proposed rule, EPA included a “no free liquids” condition for solvent

- contaminated wipes sent for disposal at a non

- land disposal unit such as a municipal waste combustor (MWC)

or other combustion unit, including use as a fuel. This condition also will apply to solvent

contaminated wipes sent to an intermediate handler for further processing to meet the “dry”

condition before disposal in a municipal or other non

- hazardous waste landfill.

Alternative Option

– “No Fre e Liquids when Wrung”

In the preamble to the proposed rule, EPA indicated that it was consider ing a ‘‘no free liquids when wrung’’ condition instead of the ‘‘no free liquids’’ condition. This approach differs from the proposed approach in that it would require that each wipe could not drip solvent when hand

wrung.

Based on comments received on the proposed rule and further analysis conducted by EPA

, EPA decided not to include the “no free liquids when wrung” condition in the final rule

, because

it carries the perception of increased worker exposure due to hand wringing. Additional ly, this standard is subjective because of the variability associated with the people doing the wringing.



## 1.4.1.7. Condition s for Intra

- Company Transfers

Propos ed Rule

To encourage recovery and recycling of the solvents in the wipes, EPA proposed to allow generators to continue to qualify for the exclusion from the definition of hazardous waste if they

transfer solvent

- contaminated wipes containing “free l iquids” between their own facilities and if

### 18 

## the receiving facility has a solvent extraction and/or recovery process that will remove sufficient solvent to ensure the wipes meet either the “dry” condition or the “no free liquids” condition before being sent off

- site.

Alternative Option

– Additional Recordkeeping and Container Conditions

In the preamble to the proposed rule, EPA indicated that it was consider ing adding conditions to

this provision. Specifically, EPA considered: (1) r equiring a one

- time notification to the s tate to

alert the s tate that the generator is taking advantage of the intra

- company transport allowed

under this exclusion; (2) m aintenance of appropriate business records that identify where the wipes are being managed and where the r ecovered solvent is being sent; (3) c ompliance with

RCRA’s employee training and emergency r esponse requirements in 40 CFR P art 262; and (4) t ransfer of the wipes with free liquids in closed (i.e., sealed) containers.

Based on comments received on the proposed rule and further analysis conducted by EPA

, EPA decided to prohibit intra

- company transfers of solvent

- contaminated wipes. Th is ensures consistency with the existing hazardous waste regulations

. Currently, EPA i s not allowing liquid

solvent to be sent off

- site without a manifest and to a facility without a RCRA permit

.



## 1.4.2. Exclusion from the Definition of Hazardous Waste for Reusable and

Solvent

- Contaminated Disposable Wipes

In the preamble to the proposed rule 16



## , EPA indicated that it was consider ing an alternative approach that would exclude reusable wipes from the regulatory definition of hazardous waste

rather than exclude them from the regulatory definition of solid waste, using the same conditions as those spe cified in the proposed rule. This approach would not differentiate the regulatory

status of solvent

- contaminated wipes whether they are being sent for recycling or for disposal. Under this approach, the provisions of the rule concerning solvent

- contamina ted disposable wipes would remain the same as in the proposed option. For solvent

- contaminated reusable wipes, the conditions for complying with the rule would be the same as in the proposed option,

but the solvent

- contaminated reusable wipes would remain solid wastes (though not hazardous wastes) when the conditions were met.

Based on comments received on the proposed rule and further analysis conducted by EPA

, EPA decided not to move forward with this approach. EPA decided that solvent

- contaminated

reusable wipes are commodity

- like and not being discarded

. EPA decided that the conditions

for the exclusion from solid waste are appropriate because they ensure that the manner in which generators and laundries manage these materials is consistent with h ow companies

would manage a commodity.

16 

### U.S. Government Printing Office. Federal Register . “ Hazardous Waste Manage ment System: Identification and Listing of Hazardous Waste: Conditional Exclusions From Hazardous Waste and Solid Waste for

Solvent

- Contaminated Industrial Wipes. ” 68 FR 65586. November 20, 2003.

### 19 

## 1.4.3. Exclusion f rom the Definition of Hazardous Waste for All Solvent

Contaminated Disposable Wipes u nder a Single Set of Conditions

In the preamble to the proposed rule 17



## , EPA indicated that a n additional approach considered was providing an exclusion from the definition of hazardous waste for all disposable wipes

under a single set of conditions. The option affected only the exclusion from the definition of
hazardous waste; all provisions for solvent

- contaminated reusable wipes would remain the

same. Under this approach

, EPA would not differentiate between wipes managed in municipal

and other non

- hazardous waste landfills or non

- landfill facilities

— the conditions necessary for wipes to obtain an exclusion from hazardous waste regulations would be the same for both types of management.

Based on comments received on the proposed rule and further analysis conducted by EPA

, EPA decided not to move forward with this approach. EPA decided that additional conditions

should be included for the land disposal of solvent

- contaminated wipes (e.g., landfills must be regulated under 40 CFR Part 258 , including 40 CFR 258.40 ) in order to provide adequate
protect ion to human heal th and the environment.

17 

### U.S. Government Printing Office. Federal Register

. “ Hazardous Waste Management System: Identification and Listing of Hazardous Waste: Conditional Exclusions From Hazardous Waste and Solid Waste for

Solvent

- Contaminated Industrial Wipes. ” 68 FR 65586. November 20, 2003.

### 20 

# 2. Characterization of Generators and Handlers of Solvent

Contaminated Wipes

This chapter characterizes the entities that may be affected by the final rule . These entities

include:

• Generators of solvent

- contaminated wipes. These include facilities that use reusable

and/or di sposable wipes in conjunction with hazardous solvents. For solvent

contaminated wipes to be eligible for the conditional exclusions under the final rule, generators are required to: (1) accumulate, store, and transport the solvent

contaminated wipes in n on

- leaking, closed containers 18 

## that are labeled “Excluded

Solvent

- Contaminated Wipes;” (2) accumulate the solvent

- contaminated wipes for up to 180 days from the start date of accumulation for each container prior to being sent for cleaning or disposal ; and (3) ensure that the solvent

- contaminated wipes contain “no free liquids” at the point of being sent for cleaning on

- site , at the point of being transported off

- site for cleaning or at the point of being transported for disposal

. Free liquids removed from the solvent

- contaminated wipes or from the container holding the wipes must be managed in accordance with the applicable regulations found in 40 CFR

P arts 260 through 273 . Generators also must comply with a few recordkeeping

requ irements.

• Handlers of solvent

- contaminated wipes. These include industrial laundries and dry

cleaners that clean solvent

- contaminated reusable wipes

, and solid waste management facilities that manage solvent

- contaminated disposable wipes once they have been discarded (i.e., hazardous and non

- hazardous landfills/combustors). Under the final rule, handlers are required to manage the solvent

- contaminated wipes in non

- leaking,

closed containers that are labeled “Excluded Solvent

- Contami nated Wipes.” Free liquids

removed from the solvent

- contaminated wipes or from the container holding the wipes must be managed in accordance with the applicable regulations found in 40 CFR Parts 260 through 273

.

The remainder of this chapter i s organized into three sections. Section 2.1 identifies the industries that may be affected by the final rule. Section 2.2 estimates the number of facilities that generate solvent

- contaminated w ipes , and the number of solvent

- contaminated wipes generated each year. Section 2.3 estimates the number of facilities that handle solvent

c ontaminated w ipes

.

Exhibit 2

- 1 illustrates the flow of wipes between generators and handlers of solvent

contaminated reusable and disposable wipes pre

- and post

- final rule.

18 

### The containers must be able to contain free liquids, should free liquids occur. During accumulation, a container is considered closed when there is complete contact between the fitted lid and the rim, except when it is necessary to add or remove solvent

- contaminated wipes. When the container is full, or when the solvent

contaminated wipes are no longer being accumulated, or when the container is being transported, the container must be sealed with all lids properly and securely affixed to the container and all openings tightly bound or closed sufficiently to prevent leaks and emissions.

### 21 Generators of

Solvent

- Contaminated

Reusable

Wipes Generators of

Solvent

Contaminated

Reusable AND
Disposable

Wipes Generators of

Solvent

- Contaminated
Disposable

Wipes

Hazardous

Waste Management

Facilities

(Landfills and
Combustors)

Industrial Laundries
and Dry Cleaners Soiled,
Reusable Wipes Clean,
Reusable Wipes

Soiled, Reusable Wipes

at End of Lifespan Soiled, Discarded Wipes

Generators of

Solvent

- Contaminated

Reusable

Wipes Generators of

Solvent

Contaminated

Reusable AND
Disposable

Wipes Generators of

Solvent

- Contaminated
Disposable

Wipes

Hazardous

Waste Management

Facilities

(Landfills and
Combustors)

Industrial Laundries
and Dry Cleaners Soiled,
Reusable Wipes Clean,
Reusable Wipes

Soiled, Reusable Wipes
at End of Lifespan Soiled, Discarded Wipes 

### Pre

- Rule Post

- Rule

Non

- Hazardous

Waste Management

Facilities

(Landfills and
Combustors) 

## Exhibit 2

- 1

Flow of Wipe s between Generators and Handlers

of Solvent

- Contaminated Wipes Pre

- and Post

- Final Rule a

a Exhibit is a general representation of the flow of wipes between generators and handlers of solvent

- contaminated wipes pre

- and
post

- final rule. The exhibit is not meant to illustrate all possible scenarios.

### 22 

## 2.1. Industries That Generate or Handle Solvent

- Contaminated Wipes

EPA identified 121 industries (based on five

- or six

- digit North American Industry Classification System (NAICS) codes 19 

## ) that may generate or handle solvent

- contaminated wipes and, therefore, may be affected by the final rule. In identifying these industries, EPA used

information derived through a literature search and discussions with key stakeholder s and industry contacts. Another important source of information was EPA’s Office of Enforcement and Compliance Assistance (OECA) Industry Sector Notebooks , which identified potential
generators of solvent

- contaminated wipes by industry. 20 

## This source als o identified industry, Regional EPA, and s tate contacts who further assisted in describing the universe of generators

of solvent

- contaminated wipes

. 21

, 22



## Exhibit 2

- 2 identifies the NAICS codes associated with the 121 industries that generate or

handle solv ent

- contaminated wipes. A description of each of these NAICS codes is provided in Appendix A. I n order to facilitate subsequent discussions , the 121 industries that generate or

handle solvent

- contaminated wipes are grouped into 15 economic sub

- sectors (b ased on three

digit NAICS code), as identified in the exhibit.

19 

### NAICS is the standard used by Federal statistical agencies in classifying business establishments for the purpose of collecting, analyzing, and publishing statistical data related to the U.S. busin ess economy.

20 

### OECA’s Industry Sector Notebooks is a set of profiles that integrate processes, applicable regulations

, and other relevant environment information for specific industries. For additional information on this data source,

refer to EPA’s “Sec tor Notebook” Web page at http://www.epa.gov/compliance/resources/publications/assistance/sectors/notebooks/ , last accessed on October 19,

2011.

21 

### U.S. Environmental Protection Agency

. Technical Background Document

- Proposed Exclusions from

the Definition of Hazardous Waste and Solid Waste for Solvent

- Contaminated Industrial Wipes . August 20, 2003. pp. 25

- 26.

22 

### U.S. Environmental Protection Ag ency

. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation

. July 17, 2003. pp. 62

- 65.

### 23 

## Exhibit 2

- 2

Industries that Generate or Handle Solvent

- Contaminated Wipes

Economic Sub

- Sector s (3

- Digit NAICS Code s ) Industries that Generate or Handle

Solvent

- Contaminated Wipes ( 5

- or 6

- Digit NAICS Code) a 

### Industry

Count

Economic Sub

- Sectors with Generators of Solvent

- Contaminated Wipes

Printer

Printing 323110, 323111, 323112, 323113, 323114, 323115,
323116, 323117, 323118, 323119, 323121, 323122 12

Publishing (printed matter) 51111, 51112, 51113, 51114, 51119 5

Business services (copy shops) 561439 1

Non

- Printer

Chemical and Allied Products 211112, 32511, 32512, 325131, 325132, 325181,
325182, 325188, 325191, 325192, 325193, 325199,
325998, 331311 14

Plastics and Rubber 31332, 315299, 315999, 325991, 326113, 326121,
32613, 32614, 32615, 32616, 326199, 326191, 326192,
326211, 32622, 326291, 326299, 337215 b 

### , 339113,
339932, 339991 21

Fabricated Metal Products 332812, 332813, 339911, 339912, 339914 5

Industrial Machinery and Equipment 314999, 332323, 33241, 332991, 333111, 33312,
33322, 333295, 333298, 333319, 333414, 333511,
333512, 333513, 333514, 333515, 333518, 333911,
333923, 333999, 33651 21

Furniture and Fixtures 337110 , 337121, 337122, 337124, 337127, 337211,
337212, 337215 b 

### 8

Auto Dealers (retail trade) 44111, 44112 2

Military Bases 92812 1

Electronics and Computers 334411, 334412, 334413 3

Transportation Equipment 332912, 336111, 336112, 336211, 33633, 33634,
336399, 336312, 336411, 336412, 336414, 336415,
336419, 336612, 336992, 48839, 54171, 81149 18

Auto Repair and Maintenance 811111, 811112 2

**Subtotal 113** 

Economic Sub

- Sectors with Handlers of Solvent

- Contaminated Wipes

Solid Waste Management Hazardous Wastes 562112, 562211 2

Non

- Hazardous Wastes 562111, 562212, 562213, 562219, 56292 5

Linen Supply and Laundering 812332 1

**Subtotal 8** 

Total 121

a A description of each of the NAICS codes is provided in Appendix A

.

b NAICS code 337215 (i.e., s howcase, partition, shelving, and locker manufacturing ) is associated with two economic sub

- sectors: “plastics

and rubber” and “furniture and fixtures.”

Source: U.S. Environmental Protection Agency

. Economics Background Document

- Estimate of National Economic Impact for Conditional

Exclusion o f Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. pp. 62

- 65.

### 24 

## This analysis characterizes each of the economic sub

- sectors with generators or handlers of

solvent

- contaminated wipes by compiling information on the number of firms (or companies)

, number of establishments (or facilities) , employment, and estimated receipts (or revenues).

This information is summarized in Exhibit 2

- 3. Unless otherwise noted, the information in the

exhibit comes from 2007 Statistics of U.S. Bu sinesses (SUSB) data develo ped by the U.S.

Census Bureau. 23



## Note that Exhibit 2

- 3 presents information for the entire economic sub

- sector s . However, not all

facilities within a sub

- sector generate or handle solvent

- contaminated wipes. The information i n
Exhibit 2

- 3 is used in Sections 2.2 and 2.3 to estimate the number of generators and handlers of

solvent

- contaminated wipes.

23 

### U.S. Census Bureau. “ Statistics of U.S. Businesses (SUSB ); ” 2007 Annual Data; U.S., Six

- D igit NAIC S

Code. Available at : http://www.census.gov/econ/susb/data/susb2007.html , last accessed on December 6 , 2011.

### 25 

## Exhibit 2

- 3

Economic Characteristics of Sub

- Sectors with

Generators or Handlers of Solvent

- Contaminated Wipes , 2007 a



### Economic Sub

- Sector s Number of

Firms (Companies) Number of

Establishments (Facilities) Employment Estimated Receipts ($1,000) g



### Economic Sub

- Sectors with Generators of Solvent

- Contaminated Wipes

Printers

Printing 31,895 33,281 631,771 $108,140,889

Publishing (printed matter) 17,039 23,082 688,034 $155,742,994

Business services (copy shops) 3,075 5,696 73,324 $8,561,922

Subtotal 52,009 62,059 1,393,129 $272,445,805

Non

- Printers

Chemical and Allied Products 2,792 4,121 181,711 $284,974,674

Plastics and Rubber b 

### 15,746 18,508 1,003,327 $259,532,444

Fabricated Metal Products 7,496 7,865 148,747 $31,827,568

Industrial Machinery and Equipment 20,686 21,736 700,954 $218,290,937

Furniture and Fixtures b 

### 18,557 18,985 413,180 $63,926,562

Auto Dealers (retail trade) 46,623 51,236 1,273,660 $800,765,408

Military Bases 5 c 

### 280 d 

### 1,126,866 e, f 

### $0

Electronics and Computers 1,601 1,761 186,734 $83,953,489

Transportation Equipment 27,618 32,552 1,568,893 $662,279,245

Auto Repair and Maintenance 79,988 83,380 348,239 $42,278,290

Subtotal 221,112 240,424 6,952,311 $2,447,828,617

Total 273,121 302,483 8,345,440 $2,720,274,421

Economic Sub

- Sectors with Handlers of Solvent

- Contaminated Wipes

Solid Waste Management Hazardous Wastes 823 1,331 33,304 $7,528,103

Non

- Hazardous Wastes 8,464 11,315 215,248 $51,601,549

Linen Supply and Laundering 503 2,857 107,732 $10,113,579

Total 9,790 15,503 356,284 $69,243,230

Grand Total 282,911 317,986 8,701,724 $2,789,517,651

a Unless otherwise noted, information presented in the exhibit is based on data contained in the following data source: U.S. Census B ureau. “Statistics of U.S. Businesses (SUSB);” 2007 Annual Data; U.S., Six

- Digit NAICS Code. Available at http://www.census.gov/econ/susb/data/susb2007.html , last accessed on

December 6 , 2011.

b NAICS code 337215 ( i.e., showcase, partition, shelving, and locker manufacturing) is associated with two economic sub

- sectors: “plastics and rubber” and “furniture and fixtures.” For purposes of this analysis, SUSB data for NAICS code 337215 were divided among these two econom ic sub

- sectors.

c Number of military base “firms” consists of the five branches o f the U.S. Armed Forces: (1) Army, (2) Navy, (3) Air Force, (4) Marine Corps, and (5) Coast

Guard.

d MilitaryBases.com. “Military Base Directory.” Available at http://militarybases.com/ , last accessed on October 19, 2011. Number includes domestic locations only.

e Employment data for Army, Navy, Air Force, and Marine Corps obtained from the following data source : U.S. Department of Defense, Defense Manpower Data Center, Statistical Information Analysis Divisi on. “Active Duty Military Personnel Strengths by Regional Area and by Country (309A).” June 30, 2011. Available

at http://siadapp.dmdc.osd.mil/personnel/MILITARY/miltop.htm , last a ccessed on October 19, 2011. Number includes domestic locations only.

f Employment data for Coast Guard obtained from the following data source: U.S. Department of Defense, Defense Manpower Data Center, Statistical Information Analysis Division. “Arm ed Forces Strength Figures for August 31, 2011.” Available at http://siadapp.dmdc.osd.mil/personnel/MILITARY/miltop.htm

, last accessed on October 19, 2011.

g Estimated receipts were updated from 2007 to 2011 dollars using the following data source: U.S. Department of Commerce, Bureau of Economic Analysis. “Table 1.1.9. Implicit Price Deflators for Gross Domestic Product.” Available online at: http://www.bea.gov/nat ional/nipaweb/TableView.asp?SelectedTable=13&Freq=Qtr&FirstYear=2006&LastYear=2008, last accessed on November 16, 2011. Year 2007, Quarter IV = 106.958 and Year 2011, Quarter III = 113.823.

### 26 

## 2.2. Generation of Solvent

- Contaminated Wipes

Thi s analysis estimat es that , each year, 90,549 facilities generat e solvent

- contaminated wipes. Collectively, these facilities generate 2.2 billion solvent

- contaminated wipes each year . The

remainder of this section describes how these estimates were derived.



## 2.2.1. Number of Gene rators of Solv ent

- Contaminated Wipes

In estimating the number of generators of solvent

- contaminated wipes, this analysis employs the following assumptions used in the economic background document originally developed for the proposed rule. 24 

## These assumptions were used in the derivation of the landfill loading estimates that serve as the basis for the risk analysis developed in support of the final rule. 25



## • 100 percent of printer facilities and 30.4 percent of non

- printer facilities g enerate solvent

contaminated wipes

. 26

, 27

, 28



## • Sixty

- seven percent of the facilities that generate solvent

- contaminated wipes are either large quantity generators (LQGs) or small quantity generator s (SQG s). 29

, 30

, 31

24 

### U.S. Environmental Protection Agenc y. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation

. July 17, 2003. pp. 92

- 93.

25 

### SAIC. Landfill Loadings Calculations For Solvent

- Contam inated Wipes . Prepared for the U.S. Environmental Protection Agency, Office of Resource Conservation and Recovery. July 2010. pp. 17

- 19.

26 

### The economic background document originally developed for the proposed rule assumes that 100 percent of printers and 35 percent of printers generate solvent

- contaminated wipes. These were ORCR’s “best estimates” of the percent of facilities that generate solvent

- contaminated wipes, based on information supplied by industry contacts familiar with wipe usage, industr ial site visits, EPA industrial inspectors, and Uniform and Textile Services Association (UTSA) “Customer Profile Analysis for 1996.” U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Condition al Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 69.

27 

### Based on overall average values from the economic background document for the proposed rule, the landfill loading report assumes that 33.5 perce nt of printer and non

- printer facilities generate solvent

- contaminated wipes in states that are expected to adopt the final rule. If the state adoption assumption (i.e., 75 percent of facilities are located in states that are expected to adopt the final r ule) is not taken into account, 44.7 percent of printer and

non

- printer facilities generate solvent

- contaminated wipes. SAIC. Landfill Loadings Calculations For Solvent

Contaminated Wipes . Prepared for the U.S. Environmental Protection Agency, Office of Resource Conservation and Recovery. July 2010. pp. 17

- 19.

28 

### To be consistent with the assumptions used in the landfill loading report, an adjustment was made to the percent of non

- printers that generate solvent

- contaminated wipes. For purposes of thi s analysis, it is assumed that 30.4 percent of non

- printers generate solvent

- contaminated wipes.

29 

### This assumption was obtained from the landfill loading report, and is based on overall average values

from the economic background document for the propos ed rule. In particular, the landfill loading report divides the number of LQGs and SQGs that generate solvent

- contaminated wipes by the total number of generators of solvent

contaminated wipes. SAIC. Landfill Loadings Calculations For Solvent

- Contaminat ed Wipes . Prepared for the U.S. Environmental Protection Agency, Office of Resource Conservation and Recovery. July 2010. pp. 17

- 19. U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 93.

30 

### LQGs are facilities that generate 1,000 kilograms (2,200 pounds or 1.10 tons) or more of hazardous waste in any single calendar month, or more than 1 kilogram (2.2 pounds or 0.001 ton) of acute hazardous waste in any single calendar month, or more than 100 kilograms (220 pounds or 0.11 ton) of acute hazardous waste spill

clean

- up material in any single calendar month.

### 27 

## Based on the above assumptions and the data presen ted in Exhibit 2

- 3, 135,148 facilities ( 62,059 printers and 73,089 non

- printers) generated solvent

- contaminated wipes in 2007. 32 

## Of
these facilities, 90,549 were either LQGs or SQGs and may be subject to the requirements of

the final rule.

Because t he regulations that apply to hazardous waste generators depend on their generator status (e.g., LQG or SQG), generators of solvent

- contaminated wipes were divided into LQGs or SQGs. To identify LQGs that generated solvent

- contaminated wipes in 2007, the a nalysis relied on data from the 2007 Hazardous Waste Report (also known as the Biennial Report or BR). 33

, 34


## BR data were queried to identify hazardous waste streams for which the waste description contained the following key words: “rags,” “wipe,” “cloth, ” and/or “towel.” In addition, the hazardous waste stream had to be either: (1) a listed F0 01

- F005 hazardous waste solvent, (2) contain a corres ponding P

- or U

- listed solvent, or (3) exhibit only the hazardous waste characteristic of ignitability (i.e., be reported as a “D001” waste)

. Exhibit 1

- 1 lists the Federal

hazardous waste codes associated with solvent

- contaminated wipes. Based on the query criteria, a total of 576 LQGs in the identified economic sub

- sectors generated solvent

contaminated wipes in 2007. As part of this query, information was obtained on the distribution of these 576 LQGs among the identified economic sub

- sectors. By subtracting the number of LQGs from the total number of LQGs and SQGs, EPA determined that a total of 89,973 SQGs generated solvent

- contaminated wipes in 2007.

The analysis then assumes that 92 percent of the generators of solvent

- contaminated wipes use primarily reusable wipes and eight percent use primarily disposable wi pes

. 35

, 36 

## Exhibit 2

- 4 illustrates the steps taken in the derivation of the number of generators of solvent

- contaminated wipes.

31 

### S QGs are facilitie s that generate between 100 kilograms (220 pounds or 0.11 ton) and 1,000 kilograms (2,200 pounds or 1.10 tons) of hazardous waste in any single calendar month.

32 

### Overall, 44.7 percent of the printer and non

- printer facilities (i.e., 135,148 / 302, 482) generated solvent

contaminated wipes.

33 

### Th e BR must be submitted by LQGs every two years (e.g., 2005, 2007, 2009). As part of this submission, LQGs provide detailed data on the types and quantities of hazardous waste they generated during the reporting year

.

34 

### U.S. Environmental Protection Agency . RCRA Info/Biennial Report, Generation and Management (GM) Forms (Section 1). Data current as of February 17

- 21, 2011

.

35 

### U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation

. July 17, 2003. pp. 92

- 93.

36 

### This assumption was obtained from the landfill loadings report, and is based on overall average values

from the economic background document for the proposed rule. In particular, the landfill loadings report divides the number of generators of solvent

- contaminated reusable or disposable wipes by the total number of generators of

solvent

- contaminated wipes. SAIC. Landfill Loadings Calculations For Solvent

- Contaminated Wipes . Prepared for the U.S. Environmental Protection Agency, Office of Resource Conservation and Recovery. July 2010. pp. 17

- 19. U.S. Environmental Protection Agency. Economics Backgrou nd Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 93.

### 28 

## Exhibit 2

- 4

Derivation of the Number o f Generators of Solve nt

- Contaminated Wipes

Number Establishments (Facilities ) in Economic Sub

- Sectors

with Generators of Solvent

- Contaminated Wipes
(U.S . Census Bureau, 2007 SUSB Data)

302,483

Printers

62,059 Non

- Printers

240,424

Generators Solvent

Contaminated Wipes

62,059 Generators Solvent

Contaminated Wipes

73,089 100% 30.4%

67%



### Legend

All Generators of 

### Solvent

- Contaminated Wipes 

### LQGs (2007 BR)

576 SQGs

89,973

Use
Primarily

Reusable

Wipes

530 Use
Primarily
Disposable

Wipes

46 92% 8 %



### Use
Primarily

Reusable

Wipes

82,775 Use
Primarily
Disposable

Wipes

7,198 92% 8 % 

### All Generators of Solvent

Contaminated Wipes

Printers and Non

- Printers)

135,148

LQGs and SQGs

90,549

### 29 

## Exhibit 2

- 5 shows the number of generators of solvent

- contaminated wipes for each of the

identified economic sub

- sectors.

Exhibit 2

- 5

Number of Generators of Solvent

- Contaminated Wipes

in Identified Economic Sub

- Sectors

Economic

Sub

- Sector s LQGs SQGs Total (LQGs and SQGs)

Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Subtotal Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Subtotal Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Total

Printers

Printing 39 3 42 20,475 1,781 22,256 20,514 1,784 22,298

Publishing (printed matter) 1 0 1 14,227 1,237 15,464 14,228 1,237 15,465

Business services (copy shops) 2 0 2 3,509 305 3,814 3,511 305 3,816

Subtotal 42 3 45 38,211 3,323 41,534 38,253 3,326 41,579

Non

- Printers

Chemical and

Allied Products 51 4 55 722 63 784 772 67 839

Plastics and Rubber 100 10 110 3,367 293 3,660 3,467 303 3,770

Fabricated

Metal Products 74 6 80 1,400 122 1,522 1,474 128 1,602

Industrial Machinery and Equ ipment 29 3 32 4,044 352 4,395 4,073 354 4,427

Furniture and

Fixtures 24 2 26 3,534 307 3,841 3,558 309 3,867

Auto Dealers (retail trade) 1 0 1 9,600 835 10,435 9,601 835 10,436

Military Bases 0 0 0 52 5 57 52 5 57

Electronics and Computers 65 6 71 265 23 288 330 29 359

Transportation Equipment 143 12 155 5,957 518 6,475 6,100 530 6,630

Auto Repair and

Maintenance 1 0 1 15,623 1,359 16,982 15,624 1,359 16,983

Subtotal 488 43 531 44,564 3,875 48,439 45,051 3,919 48,970

Total 530 46 576 82,776 7,198 89,973 83,303 7,245 90,549

### 30 

## 2.2.2. Annual Number of Solvent

- Contaminated Wipes

To estimate the number of solvent

- contaminated wipes generated each year, the analysis first

estimates the annual number of solv ent

- contaminated reusable and disposable wipes generated per facility. The analysis

, then

, excludes disposable wipes used in conjunction with trichloroethylene because these wipes are not eligible for the conditional exclusion under the

final rule. 37 

## The following paragraphs describe the derivation of these estimates.

Exhibit 2

- 6 presents EPA ’s best estimates of the average annual number of solvent

contaminated wipes generated by a single facility in the identified economic sub

- sectors. These

estimates are based on overall average values from the economic background document originally developed for the proposed. 38



## Exhibit 2

- 6 Average Annual Number of Solvent

- Contaminated Wipes Generated per Facility

Economic Sub

- Sector s LQGs SQGs

Reusable

Wipes Disposable Wipes Reusable Wipes Disposable Wipes

Printers

Printing 186,100 74,200 19,800 7,900

Publishing (printed matter) 166,600 66,800 17,700 7,100

Business services (copy shops) 160,300 64,500 17,000 6,800

Chemical and Allied Products 112,000 173,600 27,700 42,900

Plastics and Rubber 113,900 176,500 28,100 43,700

Fabricated Metal Products 109,700 169,900 27,100 42,000

Industrial Machinery and Equipment 141,000 219,400 34,800 54,000

Furniture and Fixtures 111,300 172,900 27,500 42,600

Auto Dealers (retail trade) 105,500 163,700 26,100 40,400

Military Bases 126,000 171,000 31,800 46,700

Electronics and Computers 268,000 416,100 66,200 102,500

Transportation Equipment 104,000 161,500 25,700 39,900

Auto Repair and Maintenance 100,000 185,000 25,200 39,000

Source: U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003.



## The average annual number of solvent

- contaminated wipes generated per facility (Exhibit 2

- 6) was multiplied by the corresponding number of facilities ( Exhibit 2

- 5 ) in order to come up with

the total annual number of solvent

- contaminated wipes generated by faci lities in the identified

economic sub

- sectors.

37 

### The analysis does include reusable wipes used in conjunction with trichloroethylene because these wipes are eligible for the conditional exclusion under the final rule.

38 

### In particular, the analysis uses the “annual number of RCRA solvent waste industrial wipes generated per applicable establishment.” These estimates were rounded to the nearest hundred. U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Was te Regulation . July 17, 2003. p. 94.

### 31 

## Note, however, that disposable wipes used in conjunction with trichloroethylene are not eligible

for the conditional exclusion under the final rule. Based on review of several data sources on

chemical conten t in wipes, EPA estimated that, on average, 1.8 percent of disposable wipes

g enerated by the identified economic sub

- sectors contain trichloroethylene. 39 

## Therefore, the number of eligible solvent

- contaminated disposable wipes is determined by taking the to tal

number of solvent

- contaminated disposable wipes minus the number of wipes contaminated with trichloroethylene.

Exhibit 2

- 7 shows the total annual number of solvent

- contaminated wipes generated by each of

the identified economic sub

- sectors.

39 

### This assumption was obtained from the landfill loading report, and is based on information from several data sources, including the 2003 BR; industrial cleaning solvents development data; and 2004 Toxics Release

I nventory (TRI) and a similar Massachusetts program, the 2004 Toxics Use Reduction Act (TURA). SAIC. Landfill Loadings Calculations For Solvent

- Contaminated Wipes . Prepared for the U.S. Environmental Protection Agency,

Office of Resource Conservation and Recovery. July 2010. p. 16.

### 32 

## Exhibit 2

- 7

Total Annual Number of Solvent

- Contaminated Wipes Generated

by Facilities in the Identified Economic Sub

- Sector (in Millions)

Economic

Sub

- Sector s LQGs SQGs Total (LQGs and SQGs)

Reusable

Wipes Disposable Wipes Subtotal Reusable Wipes Disposable Wipes Subtotal Reusable Wipes Disposable Wipes Total

Printer

Printing 7.19 0.24 7.44 405.41 13.81 419.22 412.60 14.06 426.66

Publishing (printed matter) 0.15 0.01 0.16 251.81 8.63 260.44 251.97 8.63 260.60

Business services (copy shops) 0.29 0.01 0.31 59.66 2.04 61.69 59.95 2.05 62.00

Subtotal 7.64 0.26 7.90 716.88 24.48 741.36 724.52 24.74 749.26

Non

- Printer

Chemical and

Allied Products 5.67 0.75 6.42 19.99 2.64 22.63 25.66 3.39 29.05

Plastics and Rubber 11.39 1.73 13.12 94.61 12.56 107.17 106.00 14.30 120.30

Fabricated

Metal Products 8.07 1.07 9.14 37.95 5.02 42.97 46.02 6.09 52.11

Industrial Machinery and Equipment 4.15 0.55 4.70 140.72 18.65 159.36 144.87 19.20 164.06

Furniture and

Fixtures 2.66 0.35 3.02 97.17 12.85 110.03 99.84 13.21 113.04

Auto Dealers (retail trade) 0.10 0.01 0.11 250.56 33.12 283.68 250.66 33.13 283.79

Military Bases 0.00 0.00 0.00 1.67 0.21 1.88 1.67 0.21 1.88

Electronics and Computers 17.51 2.32 19.83 17.52 2.32 19.84 35.03 4.64 39.66

Transportation Equipment 14.83 1.97 16.80 153.10 20.30 173.40 167.93 22.26 190.19

Auto Repair and

Maintenance 0.09 0.01 0.11 393.71 52.03 445.74 393.80 52.04 445.84

Subtotal 64.47 8.77 73.24 1,206.99 159.70 1,366.69 1,271.46 168.47 1,439.93

Total 72.11 9.03 81.14 1,923.87 184.17 2,108.05 1,995.98 193.21 2,189.19

### 33 

## 2.3. Handling of Solvent

- Contaminated Wipes

Thi s analysis estimates that 359 industrial laundries / dry cleaners and 3,730 solid waste management facilities handle solven t

- contaminated wipes each year . The remainder of this

section describes the derivation of these estimates.



## 2.3.1. Number of Handlers of Solvent

- Contaminated Reusable Wipes

Based on data submitted to EPA in response to the October 27, 2009, Notice of Data

Avail ability (NODA) 40 

## , EPA estimates that, on average, a single industrial laundry or dry cleaner

processes 509,498 pounds of reusable wipes each year (i.e., 196,605 pounds of printer towels

and 312,893 pounds of shop towels). 41 

## EPA also estimates that, on average, the weight of a

solvent

- contaminated wipe generated by a printer facility is 0.11 pounds (50 grams) and that the weight of a solvent

- contaminated wipe generated by a non

- printer facility is 0.08 pounds (37.5 grams). 42 

## Thus, based on a weighted average, the weight of a solvent

- contaminated wipe is

estimated at 0.0917 pounds.

Based on the above assumptions, this analysis estimates that, collectively, industrial laundries and dry cleaners process a total of 183,031,338 pounds of solvent

- contaminated reusable wipes each year (i.e., 2.0 billion reusable wipes (Exhibit 2

- 7) x 0.0917 pounds per wipe).

To estimate the number of industrial laundries and dry cleaners that may be affected by the final
rule, EPA takes the tota l annual pounds of solvent

- contaminated reusable wipes processed by all industrial laundries/dry cleaners and divides this number by 509,498 , i.e., the pounds of

solvent

- contaminated reusable wipes processed per industrial laundry/dry cleaner each year.

B ased on this calculation, EPA estimates the number of industrial laundries/dry cleaners that may be affected by the final rule to be 359 (i.e., 183,031,338 / 509,498 ).



## 2.3.2. Number of Handlers of Solvent

- Contaminated Disposable Wipes

This analysis estimates a total of 3,730 solid waste management facilities may be affected by

the final rule. This estimate includes 1,331 hazardous waste management facilities (Exhibit 2

- 3)
and 2,399 non

- hazardous waste management facilities. The number of non

- hazardous waste

ma nagement facilities is based on data from the Waste Business Journal ’s “Directory & Atlas of

Non

- Hazardous Waste Sites 2007, ” and only includes active municipal solid waste landfills (2,264 facilities) and active solid waste combustion/ incineration facilities (135 facilities), as of

2007.

40 

### U.S. Government Printing Office. Federal Register . “Hazardous Waste Management System: Identification and Listing of Hazardous Waste: Conditional Exclusion From Hazardous Waste and Solid Waste for

Solvent

- Contaminated I ndustrial Wipes,” Notice of Data Availability (NODA). 74 FR 55163. October 27, 2009.

41 

### This estimate was obtained from the landfill loading report developed for the final rule, and is based on survey data submitted by the Textile Rental Services Associa tion of America (TRSA)

. SAIC. Landfill Loadings

Calculations For Solvent

- Contaminated Wipes . Prepared for the U.S. Environmental Protection Agency, Office of Resource Conservation and Recovery. July 2010 . p. 34.

42 

### These assumptions were obtained from the technical background document for the proposed rule, and

are based on data collected from EPA site visits

. U.S. Environmental Protection Agency

. Technical Background

Document

- Proposed Exclusions from the Definition of Hazardous Waste and Solid Was te for Solvent

- Contaminated Industrial Wipes . August 20, 2003 . p. 102.

### 34 

# 3. Existing Regulatory Environment and the Affected Universe

This chapter provides an overview of the existing regulations applicable to the generation and management of solvent

- contaminated wipes

. In addition, it establishes the regulatory baseline of the analysis

, and identifies the affected universe . This information is used in Chapters 4 and

5 to estimate the costs and benefits of the final rule.



## 3.1. Existing Regulations Applicable to Solvent

- Cont aminated Wipes

3.1.1. Federal Regulations Applicable to Generators and Handlers of

Solvent

- Contaminated Wipes

A lthough there are currently no national guidelines for the management of solvent

- contaminated wipes, numerous regulations established under the autho rity of RCRA do currently apply to generators and handlers of solvent

- contaminated wipes if they are considered to be hazardous

wastes.

The most s tringent interpretation of the F ederal regulations under RCRA would subject all the following solvent

- conta minated wipes to the hazardous waste regulations: (1) solvent

contaminated wipes that are listed as a hazardous waste under 40 CFR Part 261, Subpart D; (2) solvent

- contaminated wipes that exhibit one or more of the characteristics of hazardous

waste identified in 40 CFR Part 261, Subpart C; (3) solvent

- contaminated wipes that are a mixture of a solid waste and a listed hazardous waste; and (4) solvent

- contaminated wipes that

are a mixture of a solid waste and a characteristic hazardous waste

, and the resultant mixture

exhibits one or more of the characteristics of hazardous waste.

Under the F ederal RCRA regulations , wipes contaminated with listed hazardous waste solvents (i.e., EPA hazardous waste codes F001

- F005) 43 

## are considered to be listed hazardou s wastes, and they are required to be managed in accordance with all applicable hazardous waste management requirements (e.g., storage standards, recordkeeping, and hazardous waste manifest). In addition, wipes contaminated with spent solvents that are ha zardous wastes because they exhibit one or more of the characteristics of hazardous waste also are considered

hazardous wastes. As hazardous wastes, these solvent

- contaminated wipes are required to be managed in accordance with all applicable RCRA hazardo us waste management requirements

as well

.

EPA’s current policy with respect to the regulatory status of solvent

- contaminated wipes is to

defer the determination of whether solvent

- contaminated wipes must be managed as a solid or

hazardous waste to the EPA Regional Offices and s tate agencies due to case

- specific circumstances (e.g., type of solvent used, degree of hazard, when a spent solvent is generated,

and whether the hazardous waste mixture rule applies to a particular waste ).

The majority of the s tates have developed their own policies governing the management of

solvent

- contaminated wipes. However, a few s tates have deferred regulatory decisions regarding the management of solvent

- contaminated wipes to their respective EPA Regional

O ffices. Thu s, different regulatory schemes for solvent

- contaminated wipes apply in different

s tates.

43 

### Refer to Exhibit 1

- 1 for a description of EPA hazardous waste codes F001 through F005.

### 35 

## 3.1.2. State Policies Applicable to Generators and Handlers of

Solvent

- Contaminated Wipes

M ost s tates have developed policies that provide conditional relief for solvent

- contaminated

reusable wipes either from solid waste or hazardous waste regulations

, or set management

standards for handlers of solvent

- contaminated wipes. 44 

## An overview of existing s tate policies is provided below.



## 3.1.2.1. State Policies on Solvent

- Contaminated Reusable Wipes

Forty

- five s tates have implemented policies stating that reusable wipes contaminated with listed

or characteristic hazardous waste solvent s that are managed at industrial laundries or dry cleaners need not be managed as a hazardous waste

, as long as specific conditions are met. The remaining five s tates (Arkansas, Idaho, Maine, South Dakota, and West Virginia) regulate reusable wipes as hazardous waste if they contain a listed hazardous waste or exhibit a
hazardous waste characteristic, even when they are being laundered.

M any states that provide regulatory relief for solvent

- co ntaminated reusable wipes consider laundering to be a form of recycling and thus, exclude solvent

- contaminated reusable wipes

fro m RCRA regulation based on the s tate’s interpretation of the definition of solid waste. Other

s tates consider solvent

- contamin ated reusable wipes a solid waste, but provide conditional

exclusions from the hazardous waste r egulations. In either case, to meet the exclusion, the

solvent

- contaminated reusable wipes typically must meet at least the following criteria:

• T he wipes con tain “ no free liquids; ” and

• T he industrial laundry handling the wipes must manage its wastewater discharge s in accordance with applicable wastewater discharge requirements (i.e., the laundry must discharge its wastewaters to a POTW with an approved pretreatment program or have a wastewater discharge permit )

.

States have different policies on what constitutes “ no free liquids ” and how to make this

determination. However, the majority of s tates use the Paint Filter Liquids Test (SW

- 846 Method 9095) to make such determinations. Other specified methods for making the “no free liquids” determination include : either physical or mechanical wringing until the wipe meets the

“no drip” criterion

, the Liquids Release Test (SW

- 846 Method 9096), and the toxici ty

c haracteristic leaching procedure ( TCLP ; SW

- 846 Method 1311) . Only a few s tates consider wringing or solvent

- extraction processes applied to solvent

- contaminated wipes to remove “ free liquids ” as a form of treatment of a hazardous waste

. 45 

## Several s tates specify that removing

“ free liquids ” through evaporation or intentional drying is not allowed.

44 

### U.S. Environmental Protection Agency

. Technical Background Document

- Proposed Exclusions from

the Definition of Hazardous Waste and Solid Waste for Solvent

- Contaminated Industrial Wipes . August 20, 2003.

p. 39.

45 

### As defined at 40 CFR 260.10, “treatment” means any method, technique, or process, including neutralization, designed to change t he physical, chemical, or biological character or composition of any hazardous waste so as to neutralize such waste, or so as to recover energy or material resources from the waste, or so as to

render such waste non

- hazardous, or less hazardous; safer to t ransport, store, or dispose of; or amenable for recovery, amenable for storage, or reduced in volume.

### 36 

## A few s tates require generators to extract solvent from reusable wipes prior to sending them

off

- site to ensure that “ free liquids ” are not transported of fsite. Industrial laundries also often urge their customers to remove solvents from the wipes prior to being transported off

- site to ensure compliance with DOT hazardous materials transportation requirements and pretreatment requirements from the local PO TW

.

In many s tates , the burden of determining whether a solvent

- contaminated wipe should be managed as a hazardous waste is placed on the generator. However, some s tates specifically

maintain that industrial laundries are obligated to accept only solvent

- contaminated wipes that meet specified criteria . O therwise, the laundry is considered to be a hazardous waste
management facility and must comply with all applicable RCRA hazardous waste management requirements

. A few s tates allow on

- site laundering of solvent

- contaminated wipes by generators, provided there is an agreement on file with the s tate that allows the facility to discharge to the sanitary sewer. In addition, some s tates require contractual agreements between generators and industrial laundrie s for the generator to qualify for an exclusion from

RCRA regulation.

While the majority of s tate policies governing the management of solvent

- contaminated

reusable wipes are similar, there are some s tates with variations. 46 

## For purposes of this analysis, however, 4 5 s tates are assumed to have a conditional exclusion from the definition of

solid waste for solvent

- contaminated reusable wipes.



## 3.1.2.2. State Policies on Solvent

- Contaminated Disposable Wipes

Currently, Massachusetts is the only s tate that has a conditional e xclusion for solvent

contaminated disposable wipes

. 47 

## All other states regulate solvent

- contaminated wipes as

hazardous waste when they are contaminated with a listed solvent or exhibit a hazardous waste

characteristic

, and the wipes are desti ned for disposal. 48



## 3.2. Regulatory Baseline

As noted above, EPA’s existing policy on solvent

- contaminated wipes has led to the application

of different regulatory schemes for solvent

- contaminated wipes across the country

. Consequently, the anticipated impact of the final rule will vary by s tate

, depending on whether they have existing state policies addressing solvent

- contaminated wipes

.

Some significant state policies regarding the management of solvent

- contaminated wipes are
summarized below:

46 

### For example, in Hawaii, solvent

- contaminated reusable wipes must be managed as hazardous waste up until the point at which they are laundered. This implies that solvent

- contaminated reusable wipes would have to be managed in accordance with all applicable hazardous waste management requirements (e.g., storag e standards, recordkeeping, and hazardous waste manifest). However, this analysis does not distinguish Hawaii from other s tates that do not require the management of solvent

- contaminated reusable wipes as hazardous waste.

47 

### For additional information o n Massachusetts’ policy for solvent

- contaminated wipes, refer to Massachusetts Department of Environmental Protection’s Policy BWP

- 94

- 015, “ Poli cy for Industrial Wipers

Contaminated w ith Solvents ,” dated February 16, 1994. Available at: http://www.mass.gov/dep/recycle/laws/solwiper.htm , last accessed on November 9, 2011.

48 

### U.S. Environmental Protection Agency

. Technical Background Document

- Proposed Exclusions from

the Definition of Hazar dous Waste and Solid Waste for Solvent

- Contaminated Industrial Wipes . August 20, 2003.

p. 39.

### 37 

## • Forty

- five s tates provide regulatory relief for solvent

- contaminated reusable wipes, as long as certain basic conditions are met

.

• F ive s tates (Arkansas, Idaho, Maine, South Dakota, and West Virginia) regulate solvent

contaminated reusable wipes as hazardous waste

.

• Massachusetts is the only s tate that has a conditional exclusion for solvent

contaminated disposable wipes

. 49 

## All other states regulate solvent

- contaminated wipes

as hazardous waste when they are contaminated with a list ed solvent or exhibit a

hazardous waste characteristic

, and the wipes are destined for disposal. 50



## Under the regulatory baseline used in this analysis , it is assumed that :

• Twenty

- five percent of facilities will not be affected by the final rule, either be cause they

are located in states that have exclusions similar to the ones in EPA’s final rule, or because they are located in states that currently have no conditional exclusions for

solvent

- contaminated wipes . These states are expected to decide not to adopt EPA’s

final rule.

• Seventy

- five percent of facilities will be affected by the final rule because they are
located in states that currently have conditional exclusions for solvent

- contaminated wipes different from the exclusions in the final rule . Th ese states are expected to adopt

EPA’s final rule

.

Based on the above, this analysis assumes that 75 percent of the LQGs and SQGs that generate solvent

- contaminated wipes are located in states that are expected to adopt the final
rule, and consequently these LQGs and SQGs will incur incremental costs or savings as a result of the final rule. All wipes generated by these LQGs and SQGs will enter the non

- hazardous waste stream. These assumptions are consistent with the economic background do cument originally developed for the proposed 51 

## rule and the landfill loading s report that serves as the basis for the risk analysis developed in support of the final rule. 52

49 

### For additional information on Massachusetts’ policy for solvent

- contaminated wipes, refer to Massachusetts Department of Environmental Protection’s Policy BW P

- 94

- 015, “ Poli cy for Industrial Wipers

Contaminated w ith Solvents ,” dated February 16, 1994. Available at: http://www.mass.gov/dep/recycle/laws/solwiper.htm , last accessed on November 9, 20 11.

50 

### U.S. Environmental Protection Agency

. Technical Background Document

- Proposed Exclusions from

the Definition of Hazardous Waste and Solid Waste for Solvent

- Contaminated Industrial Wipes . August 20, 2003.

p. 39.

51 

### The economic background docume nt developed for the proposed rule assumes that 75 percent of the facilities that generate solvent

- contaminated wipes are located in states that are expected to adopt the final rule. This assumption was ORCR’s “best estimate” of the percent of facilities in states that are expected to adopt the final rule. U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . J uly 17, 2003. p. 34.

52 

### The landfill loading report developed for the final rule obtained the 75 percent state adoption assumption from the economic background document originally developed for the proposed rule. SAIC. Landfill Loadings

Calculations For Solvent

- Contaminated Wipes . Prepared for the U.S. Environmental Protection Agency, Office of Resource Conservation and Recovery. July 2010. p. 7.

### 38 

## In order to simplify the analysis, states that have conditional exclusions all are assumed to have similar conditions for their exclusions. These conditions require laundering and reuse of the

sol vent

- contaminated wipes, and that the wipes contain “no free liquids.”

Exhibits 3

- 1 and 3

- 2 show the number of generators and solvent

- con taminated wipes in states

that are expected to adopt the final rule. The estimates presented in these exhibits represent 75 percent of the generators and solvent

- contaminated wipes affected by the final rule (i.e., 75 percent of the generators in Exhibit 2

- 5 and 75 percent of solvent

- contaminated wipes in

Exhibit 2

- 7).

### 39 

## Exhibit 3

- 1

Number of Generators of Solvent

- Contaminated Wipes

in States that Are Expected to Adopt the Final Rule

Economic

Sub

- Sector s LQGs SQGs Total (LQGs and SQGs)

Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Subtotal Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Subtotal Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Total

Printers

Printing 29 3 32 15,356 1,335 16,692 15,385 1,338 16,723

Publishing (printed matter) 1 0 1 10,670 928 11,598 10,671 928 11,599

Business services (copy shops) 1 0 2 2,632 229 2,861 2,633 229 2,862

Subtotal 31 3 34 28,658 2,492 31,151 28,690 2,495 31,184

Non

- Printers

Chemical and

Allied Products 38 3 41 541 47 588 579 50 630

Plastics and Rubber 75 8 83 2,525 220 2,745 2,600 227 2,827

Fabricated

Metal Products 55 5 60 1,050 91 1,141 1,105 96 1,201

Industrial Machinery and Equipment 22 2 24 3,033 264 3,296 3,055 266 3,320

Furniture and

Fixtures 18 2 20 2,650 230 2,881 2,668 232 2,900

Auto Dealers (retail trade) 1 0 1 7,200 626 7,826 7,201 626 7,827

Military Bases 0 0 0 39 3 43 39 3 43

Electronics and Computers 49 4 53 198 17 216 247 22 269

Transportation Equipment 107 9 116 4,468 389 4,856 4,575 398 4,973

Auto Repair and

Maintenance 1 0 1 11,717 1,019 12,736 11,718 1,019 12,737

Subtotal 365 33 398 33,423 2,906 36,329 33,788 2,939 36,727

Total 397 35 432 62,081 5,398 67,479 62,478 5,434 67,911

### 40 

## Exhibit 3

- 2

Total Annual Number of Solvent

- Contaminated Wipes

in States that Are Expected to Adopt the Final Rule (in Millions)

Economic

Sub

- Sector s LQGs SQGs Total (LQGs and SQGs)

Reusable

Wipes Disposable Wipes Subtotal Reusable Wipes Disposable Wipes Subtotal Reusable Wipes Disposable Wipes Total

Printer

Printing 5.39 0.18 5.58 304.06 10.36 314.42 309.45 10.54 319.99

Publishing (printed matter) 0.11 0.00 0.12 188.86 6.47 195.33 188.98 6.47 195.45

Business services (copy shops) 0.22 0.01 0.23 44.74 1.53 46.27 44.96 1.54 46.50

Subtotal 5.73 0.20 5.92 537.66 18.36 556.02 543.39 18.55 561.94

Non

- Printer

Chemical and

Allied Products 4.25 0.56 4.81 14.99 1.98 16.97 19.24 2.55 21.79

Plastics and Rubber 8.54 1.30 9.84 70.96 9.42 80.38 79.50 10.72 90.22

Fabricated

Metal Products 6.06 0.80 6.86 28.46 3.77 32.23 34.51 4.57 39.08

Industrial Machinery and Equipment 3.11 0.41 3.53 105.54 13.98 119.52 108.65 14.40 123.05

Furniture and

Fixtures 2.00 0.26 2.26 72.88 9.64 82.52 74.88 9.91 84.78

Auto Dealers (retail trade) 0.07 0.01 0.08 187.92 24.84 212.76 187.99 24.85 212.84

Military Bases 0.00 0.00 0.00 1.25 0.16 1.41 1.25 0.16 1.41

Electronics and Computers 13.13 1.74 14.87 13.14 1.74 14.88 26.27 3.48 29.75

Transportation Equipment 11.12 1.47 12.60 114.82 15.22 130.05 125.95 16.70 142.64

Auto Repair and

Maintenance 0.07 0.01 0.08 295.28 39.02 334.30 295.35 39.03 334.38

Subtotal 48.35 6.58 54.93 905.24 119.77 1,025.02 953.59 126.35 1,079.95

Total 54.08 6.77 60.85 1,442.90 138.13 1,581.03 1,496.98 144.90 1,641.89

### 41 

# 4. Estimated Costs and Savings of the Final Rule

This chapter estimates the compliance costs and savings of the final rule. Section 4.1 summarizes the annual costs and savings of the final rule. Section 4.2 reports on these costs and savings by type of facility . Section 4.3 describes the derivation of each of the cost elements

that contri bute to total costs and savings.



## 4.1. Summary of Costs and Savings

EPA estimates the total one

- time cost of the final rule across all facilities at approximately $1.2

million (2011 dollars) . EPA also estimates the total annual costs to be approximately $ 6.3

million and the total annual savings to be approximately $ 24.4 million across all affected

facilities. EPA evaluated these costs and savings over a 10

- year period 53 

## , using real discount rates of 7 percent, 3 percent, and 0 percent. 54



## To estimate the annualized costs and savings, when payments are due at the beginning of each period

, the analysis uses the following equation :

AC = PV C x r x (1 + r) n

- 1



## (1 + r ) n



## – 1

where A C is the annualized cost (payment) accrued at the beginning of each of n periods ; PV C is the present value of costs (payments) ; r is the discount rate per period (e.g., 7 percent per year , 3 percent per year ); and n is the annualization period ( in this case, 10 years )

.

PVC is calculated by multiplying the value of the cost in each year by a time

- dependent discount

factor, d , and summing all of the discounted values as shown in the following equation:

PV C = d 0 

## V 0 

## + d 1 

## V 1 

## + d 2 

## V 2 

## + ... + d

n

– 1 

## V

n

– 1 

## + d

n 

## V

n



## where V

n 

## is the value of the cost (payment) accrued at the beginning of each of n periods . The discounting factor

, d

n 

## , is defined as :

d

n 

## = 1

(1 + r) n

- 1

53 

### Under the final rule, the only one

- time cost element is reading the regulations. All other cost and sa vings elements are estimated on an annual basis. The analysis evaluates costs and savings over a 10

- year period in order to avoid understating the impacts associated with the one

- time costs.

54 

### In annualizing the costs and benefits, the analysis uses a pr ocedure consistent with EPA’s guidelines for discounting future costs and benefits. U.S. Environmental Protection Agency. Guidelines for Preparing Economic Analyses , “Chapter 6, Discounting Future Benefits and Costs.” December 17, 2010 . Available at: http://yosemite.epa.gov/ee/epa/eerm.nsf/vwAN/EE

- 0568

- 50.pdf/$file/EE

- 0568

- 50.pdf , last accessed on December 8,

2011.

### 42 

## where r is the discount rate , and n is the number of years in t he annualization period (in this case, 10 years)

.

The analysis then uses annualized one

- time cos ts, annual costs

, and annual savings to estimate the net savings of the final rule, as follows:

Net S avings = [Annual Savings]

– ([Annualized One

- Time Costs] + [Annual Costs])

Exhibit 4

- 1 shows the annual costs and savings of the f inal rule. As shown in the exhibit, at all three discount rates, the annual net savings of the final rule are estimated to be approximately $1 8.0 million (2011 dollars).

Exhibit 4

- 1

Annual Costs and Savings of the Final Rule , 2011 Dollars a

Type of Impact s 7%

Discount Rate 3%

Discount Rate 0%

Discount Rate

Annualized One

- Time Cost b $163,630 $139,961 $122,971

Annual Costs c $6,261,270 $6,261,270 $6,261,270

Annual Savings d $24,375,585 $24,375,585 $24,375,585

Net Savings e $17,950,686 $17,974,354 $17,991,344

a Costs and savings are evaluated over a 10

- year period.

b One

- time costs include: reading the final rule. Total one

- time costs for all affected facilities are presented in Exhibit 4

- 4 of this document.

c Annual costs include: (1) becoming familiar with the final rule requirements and implementation procedures/practices, (2) purchase of containers, (3) purchase of labels, (4) affixing labels to containers, (5) removing "free liquids" from containers, (6) recor dk eeping requirements under the final rule, and (7) demonstrating compliance with final rule requirements. Total annual costs for all affected facilities are presented in Exhibit 4

- 4 of this document.

d Annual savings include: (1) management of “free liqu ids” removed from containers, (2) avoided hazardous waste manifest costs, (3) avoided disposal costs, (4) avoided RCRA information collection requirement costs to SQGs that may become CESQGs, and (5) avo ided

s tate waste fees and taxes. Total annual saving s for all affected facilities are presented in Exhibit 4

- 4 of this document.

e Net savings = [Annual Savings]

– ( [ Annualized On e

- Time Costs] + [Annual Costs])



## 4.2. Costs and Savings by Type of Facility

E xhibit 4

- 2 summarizes the break out of costs and savi ngs for affected facilit ies based on type of facility (i.e., LQG, SQG, or handling facility) and type of wipe (i.e., reusable or disposable )

. The exhibit also shows the per

- facility costs (savings) and number of affected facilities used to estimate total costs and savings.

### 43 

## Exhibit 4

- 2 Summary of Estimated Costs and Savings

of t he Final Rule by Type s of Facility, 2011 Dollars a

Type of Facilit ies Type of Wipe s Per

- Facility Costs (Savings) f Number of

Affected

Facilities g Total Costs (Savings)

for All Affected

Facilities h

One

- Time Costs b

LQGs Reusable Wipes $39 530 $20,412

Disposable Wipes $39 46 $1,772

SQGs Reusable Wipes $13 82,776 $1,062,634

Disposable Wipes $13 7,198 $92,402

Handling Facilities f Reusable Wipes $13 359 $4,612

Disposable Wipes $13 3,730 $47,884

Total One

- Time Costs $1,229,715

Annual Costs c

LQGs Reusable Wipes $366 397 $145,131

Disposable Wipes $469 35 $16,629

SQGs Reusable Wipes $88 62,081 $5,470,066

Disposable Wipes $95 5,398 $511,329

Handling Facilities e Reusable Wipes $39 269 $10,376

Disposable Wipes $39 2,798 $107,739

Total Annual Costs $6,261,270

Annual Savings d

LQGs Reusable Wipes $0 397 $0

Disposable Wipes $30,489 35 $1,081,147

SQGs Reusable Wipes $0 62,081 $0

Disposable Wipes $4,207 5,398 $22,711,561

Handling Facilities e Reusable Wipes $0 269 $0

Disposable Wipes $208 2,798 $582,877

Total Annual Savings $24,375,585

a Costs are rounded to the nearest whole number.

b One

- time costs include: reading the final rule.

c Annual costs include: (1) becoming familiar with the final rule requirements and implementation procedures/practices, (2) purchase of containers, (3) purchase of labels, (4) affixing labels to containers, (5) removing "free liquids" from containers, (6) recordk eeping requirements under the final rule, and (7) demonstrating compliance with final rule requirements.

d Annual savings include: (1) management of “free liquids” removed from containers, (2) avoided hazardous waste manifest costs , (3) avoided disposal costs, (4) avoided RCRA information collection requirement costs to SQGs that may become CESQGs, and (5) avoided state waste fees

and taxes.

e For solvent

- contaminated disposable wipes, handling facilities include hazardous waste management facilities, mu nicipal solid waste landfill
facilities, and solid waste combustion facilities. For solvent

- contaminated reusable wipes, handling facilities include industrial laundries and dry

cleaners.

f Per

- f acility costs (s avings) are summarized in Exhibit 4

- 3.

g F or one

- time costs, affected facilities include generators and handlers of solvent

- contaminated wipes in all states (see Sections 2.2.1 and 2.3 of this document). For annual costs and savings, affected facilities include generators and handlers of solvent

- contaminated wipes in states that are expected to adopt the final rule (see Section 3.2 of this document).

h Total Costs (Savings) for All Affected Facilities = [Per

- F acility Costs (S avings )] x [Number of Affected F acilities ].

### 44 

## For purposes of this analysis, o ne

- time costs include:

• Reading the final rule.

Annual costs include:

• B ecoming familiar with the final rule requirements and implementation procedures/practices

.

• Purchase of containers.

• Purchase of labels.

• Affixing labels to containers.

• R emoving "free liquids" from containers.

• R ecordkeeping re quirements under the final rule.

• D emonstrating compliance with final rule requirements

.

Annual savings include:

• M anagement of “free liquids” removed from containers

.

• A voided hazardous waste manifest costs.

• Avoided disposal costs.

• A voided RCRA inf ormation collection requirement costs to SQGs that may become

CESQGs.

• A voi ded s tate waste fees and taxes.

Exhibit 4

- 3 summarizes the average per

- facility costs (savings) associated w ith each of the

various cost elements that contribute to the total costs and savings . Section 4.3 describes the

derivation of the estimated average per

- facility costs (savings) for each of the se cost elements.

### 45 

## Exhibit 4

- 3 Average Per

- Facility Costs and Savings of t he Final Rule , 2011 Dollars a , b, c

Cost Element s Reusable Wipes Disposable Wipes

LQGs SQGs Handling

Facilities LQGs SQGs Handling

Facilities

One

- Time Costs

Familiarization

with the

Final Rule Reading the Final Rule $39 $13 $13 $39 $13 $13

Annual Costs

Familiarization

with the

Final Rule Becomi ng Familiar with the Final Rule Requirements and Implementation

Procedures/Practices $116 $39 $39 $116 $39 $39

Containers

for Solvent

Contaminated Wipes Purchase of Closed Containers $27 $5 Not Applicable $25 $3 Not Applicable

Purchase of Labels $152 $26 Not Applicable $140 $19 Not Applicable

Affixing Labels to Containers $63 $11 Not Applicable $59 $8 Not Applicable

Management of "Free Liquids" Removing "Free Liquids"

from Containers Not Applicable Not Applicable Not Applicable $121 $18 Not Applicable

Management of "Free Liquids"

Removed from Containers Not Applicable Not Applicable Not Applicable ($75) ($23) Not Applicable

Off

- Site Management

of Solvent

Contaminated Wipes Avoided Hazardous Waste

Manifest Costs Not Applicable Not Applicable Not Applicable ($597) ($77) ($208)

Avoided Disposal Costs Not Applicable Not Applicable Not Applicable ($29,639) ($3,970) Not Applicable

Information

Collection Requirements Recordkeeping Requirements

under the Final Rule $8 $8 Not Applicable $8 $8 Not Applicable

Demonstrating Compliance with Final Rule Requirements d $0 $0 Not Applicable Not Applicable Not Applicable Not Applicable

Avoided RCRA Information Collection Requirement Costs for SQGs that May Become CESQGs e Not Applicable Not Applicable Not Applicable Not Applicable ($113) Not Applicable

Avoided State Waste Fees and Taxes Not Applicable Not Applicable Not Applicable ($178) ($24) Not Applicable

Total Annual Costs (Savings) $366 $88 $39 ($30,020) ($4,112) ($170)

a Values in parentheses denote cost savings. Costs in the exhibit are rounded to the nearest whole number.

b In the exhibit, “

- “ means that the cost element is not applicable to the type of facility.

c Information on the derivation of the average per

- facility costs (savings) is presented in Section 4.3.

d The above exhibit presents "overall" cost per facility for demonstrating c ompliance with final rule r equirements . These estimates were obtained by dividing the total costs for all facilities subject to inspection by the number of f acilities in s tates that will a dopt the final rule

.

e The above exhibit presents "overall" cost per facility for avoided RCR A information collection requirements for SQGs that may become CESQGs. This estimate was

obtained by dividing total costs for all SQGs that may become CESQGs by the number of SQGs i n s tates that will a dopt the final rule

.

### 46 

## Exhibit 4

- 4 presents the same information for all affected facilities. Note that per

- facility costs and savings vary depending on the frequency with which the activity is conducted, the type of wipe used in conjunction with the hazardous solvent (i.e., reusable wipe vs. disposable wip e), and the type of facility generating the solvent

- contaminated wipe (i.e., LQG vs. SQG).

To estimate costs and savings for all affected facilities (e.g., the information presented in

Exhibit 4

- 4), the average per

- facility costs i n Exhibit 4

- 3 are multip lied by the applicable number

of affected facilities. For one

- time costs, affected facilities include generators and handlers of

solvent

- contaminated wipes in all states (see Sections 2.2.1 and 2.3 of this document). For annual costs and savings, affecte d facilities include generators and handlers of solvent

contaminated wipes in states that will adopt the final rule (see Section 3.2 of this document).

### 47 

## Exhibit 4

- 4 Total Costs and Savings of t he Final Rule for All Affected Facilities, 2011 Dollars a , b

Cost Element s Reusable Wipes Disposable Wipes

LQGs SQGs Handling

Facilities LQGs SQGs Handling

Facilities

One

- Time Costs

Familiarization

with the

Final Rule Reading the Final Rule $20,412 $1,062,634 $4,612 $1,772 $92,402 $47,884

Annual Costs

Familiarization

with the

Final Rule Becomi ng Familiar with the Final Rule Requirements and Implementation

Procedures/Practices $45,815 $2,390,897 $10,376 $4,097 $207,905 $107,739

Containers

for Solvent

Contaminated Wipes Purchase of Closed Containers $10,730 $286,290 Not Applicable $888 $18,120 Not Applicable

Purchase of Labels $60,091 $1,603,226 Not Applicable $4,975 $101,469 Not Applicable

Affixing Labels to Containers $25,172 $671,582 Not Applicable $2,084 $42,505 Not Applicable

Management of "Free Liquids" Removing "Free Liquids"

from Containers Not Applicable Not Applicable Not Applicable $4,288 $96,307 Not Applicable

Management of "Free Liquids"

Removed from Containers Not Applicable Not Applicable Not Applicable ($2,663) ($123,717) Not Applicable

Off

- Site Management

of Solvent

Contaminated Wipes Avoided Hazardous Waste

Manifest Costs Not Applicable Not Applicable Not Applicable ($21,175) ($413,729) ($582,877)

Avoided Disposal Costs Not Applicable Not Applicable Not Applicable ($1,051,011) ($21,434,208) Not Applicable

Information

Collection Requirements Recordkeeping Requirements

under the Final Rule $3,307 $517,756 Not Applicable $296 $45,023 Not Applicable

Demonstrating Compliance with

Final Rule Requirements $16 $315 Not Applicable Not Applicable Not Applicable Not Applicable

Avoided RCRA Information Collection Requirement Costs for SQGs that May Become CESQGs Not Applicable Not Applicable Not Applicable Not Applicable ($611,481) Not Applicable

Avoided State Waste Fees and Taxes Not Applicable Not Applicable Not Applicable ($6,297) ($128,427) Not Applicable

Total Annual Costs (Savings) $145,131 $5,470,066 $10,376 ($1,064,518) ($22,200,232) ($475,138)

a Values in parentheses denote cost savings.

b In the exhibit, “

- “ means that the cost element is not applicable to the type of facility.

### 48 

## 4.3. Derivation of Cost and Savings Elements

This section describes the derivation of the estimated per

- facility costs (savings) for each of the

cost elements that contribute to the total costs and savings. 55



## In estimating the costs and savings, the analysis uses three hourly compensation rates that include salary

, 56 

## fringe benefits (e.g., paid leave and health benefits) 57 

## , and other overhead (e.g., payroll costs) 58 

## :

• An hourly compensation rate of $51.35 (2011 dollars) is used to estimate the costs associated with: (1) reading the final rule and (2) becoming familiar with the final rule requirements and implementation procedures/practices. This hourly rate is based on the average of the hourly compensation rates for the technical, managerial, and legal labor categories. 59



## • An hourly compensation rate of $17.49 (2011 dollars) is used to estimate the costs associated with: (1) affixing labels to containers and (2) removing “free liquids” from containers. This hourly rate is based on the hourly compensation rate for janitorial and cleaning staff. 60

55 

### As noted throughout this section, i n es ti mating the per

- facility costs ( savings ) , the analysis relies on assumptions used in the economic background document originally developed for the proposed rule. ( U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Ec onomic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. ) The analysis also addresses, as appropriate, public comments received on the economic background document for the proposed rule.

56 

### The wage rates used in the derivation of the hourly compensation rates were obtained from the following

data source: Bureau of Labor Statistics. "May 2010 National Occupational Employment and Wage Estimates, United

States." Available at: http://www.bls.gov/oes/current/oes_nat.htm , last accessed on October 26, 2011. These 2010 wage rates were updated to 2011 dollars based on the following data source: Bureau of Labor Statistics. Employment Cos t Index

- Historical Listing, June 2011 ; "Table 5. Employment Cost Index for total compensation, for private industry workers, by occupation and industry; Continuous occupational and industry series (not seasonally adjusted)." Available online at: http://www.bls.gov/web/eci/ecicois.pdf , last accessed on October 26, 2011. Private Industry Workers, All Workers, June 2010=111.7 and June 2011=114.3.

57 

### The benefits multiplier used in the derivation of the hourly compensation rates was obtained from the following data source: Bureau of Labor Statistics. News Release, Employer Costs for Employee Compensation

- June 2010 ; “Table 5. Employer costs per hour worked for employee compensation and costs as a p ercent of total compensation: Private industry workers, by major occupational group and bargaining unit status, June 2010.”

Available at: http://www.bls.gov/news.release/archives/e cec_09082010.pdf , last accessed on October 26, 2011. For

all oc cupational categories, except “ janitors and cleaners, ” used data for the “ Manageme nt, professional, and related” occupational group. For “janitors and cleaners,” used data for the “ Natural re sources, construction, and

maintenance” occupational group.

58 

### The overhead multiplier used in the derivation of the hourly compensation rates was obtained from the economic background document originally developed for the proposed rule, and is based on th e average of three case studies included in two EPA full accounting reports for solid/hazardous waste management. U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional

Exclusion of Solv ent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 138.

59 

### U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RC RA Hazardous Waste Regulation

. July 17, 2003. p. 138

.

60 

### Ibid.

### 49 

## • An hourly compensation rate of $33.36 (2011 dollars) is used to estimate the costs associated with: (1) complying with the recordkeeping requirements of the final rule and (2) demonstrating compliance with the final rule requirements. This hourly r ate is based on the average of the hourly compensation rates for technical and managerial staff.

Exhibit 4

- 5 presents the hourly compensation rates for each of the labor categories mentioned above (e.g., technical, managerial, legal).

Exhibit 4

- 5 Hourly Compensation Rates, 2011 Dollars

Labor Categor ies Bureau of Labor Statistics Standard Occupational Code s a Hourly Compensation Rate s ($/hour) e

Technical 51

- 9061 $25.59

Managerial 51

- 1011 $41.13

Legal 23

- 1011 $87.34

Janitors and cleaners 37

- 2011 $17.59

a U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 138.

b 2011 Hourly Compensation Rate = [2010 Median Wage Rate ($/hour)] x [Benefits Multiplier] x [Overhead Multiplier] x [Employment Cost Index Adjustment Factor]. The “2010 median wage rate” is $15.88 for technical staff, $25.53 for managerial staff, $54.21 for le gal staff, and $10.68 for janitors and cleaners. The “benefits multiplier” is 1.292 for technical, managerial, and legal staff; and 1.321 for janitors and cleaners. The “overhead multiplier” is 1.219 for all labo r categories. The “employment cost index adjustment factor” is 1.023 for all labor categories.



## The remainder of this section describes the data and the assumptions used in the derivation of each of the per

- facility costs (savings).



## 4.3.1. Reading the Final Rule

EPA anticipates that a ll g enerators and handlers of solvent

- contaminated wipes 61


## (i.e., generators and handlers located in states that are expected to adopt the final rule and

those that are not expected to adopt the final rule) will read the final rule, or a summary of the rule (e.g., trade journal newsletter article). By reading the regulations, these facilities will identify the final rule requirements applicable to them and/or be up

- to

- date in regards to the regulations applicable to the h azardous wastes they generate or manage. To estimate the costs associated with this activity, the analysis employs the following assumptions:

• O n average, three people at a LQG facility

, one person at an SQG facility , and one person at a handling facility will need to read the final rule. 62

61 

### Handlers of solvent

- contaminated disposable wipes include hazardous waste management facilities, municipal solid waste landfill facilities, and solid waste combustion facilities. Handlers of solvent

- contaminated reusable wipes include industrial laundries and dry cleaners.

62 

### This assumptions was obtained from the economic background document developed for the proposed rule, and is based on judgment by ORCR staff. U.S. Environmental Prote ction Agency. Economics Background

Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. pp. 139

- 140.

### 50 

## • E ach designated person (i.e., a supervisor y

- level employee ) needs about 15 minutes (or 0.25 hours) to read the final rule. This takes place only in the first year after the promulgation of the final rule. 63



## • The hourly compensation rate for the designated person is estimated to be $51.35 (2011 dollars).

Exhibit 4

- 6 shows the one

- time cost per facility for reading the final rule, by type of facilities and type of solvent

- contaminated wipe s

.

Exhibit 4

- 6

One

- Time Cost per Facility for Reading the Final Rule, 2011 Dollars

Type of

Facilities Reusable Wipes b, c Disposable Wipes b, c

LQG s $39 $39

SQG s $13 $13

Handling Facilities a $13 $13

a For solvent

- contaminated disposable wipes , handling facilities include hazardous waste management facilities, municipal solid waste landfill facilities, and solid waste combustion facilities. For solvent

contaminated reusable wipes , handling facilities include industrial laundries and dry cleaners.

b Cost per Facil ity = [Number of Designated Persons per Facility] x [0.25 hours/person] x [$51.35/hour]. The “number of designated persons per facility” is 3 for LQGs, 1 for SQGs, and 1 for handling facilities.

c Costs in the exhibit are rounded to the nearest whole num ber.



## 4.3.2. Familiarizing Employees with the Final Rule Requirements and Implementation Procedures/Practices

Generators and handlers of solvent

- contaminated wipes 64 

## will need to familiarize employees

with the final rule requirements and implementation procedures/practices in order to meet the

conditions of the exclusion s

. To estimate the costs associated with this activity, the analysis employs the following assumptions:

• O n average, three people at a LQG facility

, one person at an SQG facility , and on e person at a handling facility will need to become familiar with the final rule requirements and implementation procedures/practices. 65



## • In s tates that wi sh to adopt the final rule, each designated person (i.e., a supervisor y

level employee) needs about 45 minutes (or 0.75 hours) to become familiar with the final rule requirements and implementation procedures/practices on a yearly basis

. 66

, 67

63 

### Ibid.

64 

### Handlers of solvent

- contaminated dispo sable wipes include hazardous waste management facilities, municipal solid waste landfill facilities, and solid waste combustion facilities. Handlers of solvent

- contaminated reusable wipes include industrial laundries and dry cleaners.

65 

### This assumptions was obtained from the economic background document developed for the proposed rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background

Document

- Estimate of National Economic Impact for Conditional Exclus ion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. pp. 139

- 140.

### 51 

## • This activity will be conducted by a supervisory

- level employee

, making $51.35 per hour (2011 dollars).

Exhibit 4

- 7 shows the annual cost per facility for becoming familiar with the final rule requirements and implementation procedures/practic e s, 

## by type of facilities and type of wipe s

.

Exhibit 4

- 7 Annual Cost per Facility for Becoming Familiar with the F inal Rule Requirements a nd Implementation Procedures/Practices , 2011 Dollars

Type of

Facilities Reusable Wipes b, c Disposable Wipes b, c

LQG s $116 $116

SQG s $39 $39

Handling Facilities a $39 $39

a For solvent

- contaminated disposable wipes , handling facilities include hazardous waste management facilities, municipal solid waste landfill facilities, and solid waste combustion facilities. For solvent

contaminated reusable wipes , handling facilities include industrial laundries and dry cleaners.

b Cost per Facility = [Number of Designated Persons per Facility] x [0.75 hours/person] x [$51.35/hour]. The “number of designated persons per facility” is 3 for LQGs, 1 for SQGs, and 1 for handling facilities.

c Costs in the exhibit are rounded to the nearest whole number.



## 4.3.3. Purchase of Containers

To be eligible for the conditional exclusions, solvent

- contaminated wipes must be accumulated, stored, and transported in non

- leaking, closed containers. 68 

## The containers must be able to contain liquids, should liquids occur. In order to satisfy this condition, facilities may need to purchase closed containers for solvent

- contaminated wipes.

To estimate the costs associated with the purchase of closed containers for solvent

contaminated wipes, the analysis employs the following assumptions:

• When considering the type of container to be used for accumulating, storing, and/or transporting solvent

- contaminated wipes, facilities will opt for the least costl y behavior,

66 

### Ibid.

67 

### The economic background document originally developed for the proposed rule assumes that each designated person will need 30 minutes (or 0.50 ho urs) to become familiar with the rule requirements

. This analysis

assumes that an additional 15 minutes (or 0.25 hours) per person will be required to become familiar with implementation procedures/practices needed to meet the conditions of the exclusion s

.

68 

### The containers must be able to contain free liquids, should free liquids occur. During accumulation, a container is considered closed when there is complete contact between the fitted lid and the rim, except when it is necessary to add or remove so lvent

- contaminated wipes. When the container is full, or when the solvent

contaminated wipes are no longer being accumulated, or when the container is being transported, the container must be sealed with all lids properly and securely affixed to the conta iner and all openings tightly bound or closed sufficiently to prevent leaks and emissions.

### 52 

## which is the use of plastic bags. 69 

## Currently, b ags are used by facilities to accumulate,

store, and transport hazardous waste

. 70

, 71



## • On average, each LQG facility generates about 136,384 solvent

- contaminated reusable wipes per year; each SQG fa cility generates about 23,2 42 solvent

- contaminated

reusable wipes per year. 72 

## EPA estimates that, on average, each 34

- gallon plastic bag has a loading capacity of 756 solvent

- contaminated reusable wipes. 73

, 74 

## To estimate

the total annual number of containers needed at each facility, the analysis takes the

average annual number of solvent

- contaminated reusable wipes generated per facility

and divide d it by the loading capacity of a 34

- gallon plastic bag . Base d on this calculation, EPA estimates that each LQG facility will need a total of 180 containers per year (i.e., 136,384 wipes per year / 756 wipes per plastic bag ); each SQG facility will need a total of 31 containers per year (i.e., 23,24 2 wipes per year / 756 wipes per plastic bag ).

• On average, each LQG facility generates about 191,008 solvent

- contaminated disposable wipes per year; each SQG facility generates about 25,5 87 solvent

contaminated disposable wipes per year. 75 

## EPA estimates that, on average, each 34

- gallon plastic bag has a loading capacity of 1,144 solvent

- contaminated disposable wipes. 76 

## To estimate the total annual number of containers needed at each facility, the

69 

### Per EPA guidance, a plastic bag is considered a “closed” container when it is “sealed to the extent necessary to keep the hazardous waste and associated air emiss ions inside the container” (e.g., the neck of the bag is tightly bound). U.S. Environmental Protection Agency. Memorandum from Robert Dellinger, Director of Materials Recovery and Waste Management Division, to RCRA Division Directors of Regions 1

- 10 on “ Guidance on 40 CFR

264.17 3(a) and 265.173(a): Closed Containers.” December 3, 2009. Available at: http://yosemite.epa.g ov/osw/rcra.nsf/0c994248c239947e85256d090071175f/DC2AFFCA7960F08A8525795F00610E E7/$file/14826.pdf , last accessed on December 15, 2011.

70 

### U.S. Environmental Protection Agency. Memorandum from Robert Dellinger, Director of Materials Recovery and Waste M anagement Division, to RCRA Division Directors of Regions 1

- 10 on “ Guidance on 40 CFR

264.17 3(a) and 265.173(a): Closed Containers.” December 3, 2009. Available at: http://yosemite.epa.gov/osw/rcra.nsf/0c994248c239947e85256d090071175f/DC2AFFCA7960F08A8525795F00610E E7/$file/14826.pdf , last accessed on December 15, 2011

71 

### U.S. Government Printing Office. Federal Register

. “ Hazardous Waste Management System: Identification and Listing of Hazardous Waste: Conditional Exclusions From Hazardous Waste and Solid Waste for

Solvent

- Contaminated Industrial Wipes. ” 68 FR 65586. November 20, 2003. p. 65596.

72 

### These estimates are based on the annual number of solvent

- contaminated reusable wipes in Exhibit 3

- 2 and the number of generators of solvent

- contaminated reusable wipes in Exhibit 3

- 1 of this document. Note that, due to rounding error, the reader may not obtain the same estimates provided in this bullet.

73 

### This assumptions was obtained from the economic background document developed for the proposed rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background

Document

- Estim ate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 145.

74 

### Based on data submitted to EPA in response to the October 27, 2009 Notice of Data Availability (NODA),

t he weight of a solvent

- contaminated reusable wipe is estimated to be 0.0917 pounds. As a result of this revision, the loading capacity in the economic background document originally developed for the proposed rule has been revised from 554 wipes per conta iner to 756 wipes per container.

75 

### These estimates are based on the annual number of solvent

- contaminated disposable wipes in

Exhibit 3

- 2 and the number of generators of solvent

- contaminated disposable wipes in Exhibit 3

- 1 of this document.
Note that, du e to rounding error, the reader may not obtain the same estimates provided in this bullet.

76 

### This assumptions was obtained from the economic background document developed for the proposed rule, and is based on judgment by ORCR staff. U.S. Environmental P rotection Agency. Economics Background

### 53 

## analysis takes the average annual number of solvent

- contaminated disposable wipes generated per facility and divided it by the loading capacity of a 34

- gallon plastic bag. Based on this calculation, EPA estimates that each LQG facility will need a total of 167 containers per year (i.e., 191,008 wi pes per year / 1,144 wipes per plastic bag); each SQG facility will need a total of 22 containers per year (i.e., 25,587 wipes per year / 1,144 wipes per container).

• Currently, EPA estimates that 50 percent of solvent

- contaminated reusable and disposable wipes are not accumulated, stored, and/or transported in closed containers. 77


## Therefore, facilities will need to purchase 50 percent of the total number of closed

containers needed for solvent

- contaminated reusable and disposable wipes.

• Plastic bags are p urchased and used once by generators to accumulate, store, and transport solvent

- contaminated wipes. 78 

## The same plastic bags are then used to manage the solvent

- contaminated wipes at the handling facilities.

• The cost of a 34

- gallon plastic bag is $0.30 (2011 dollars). This cost is based on the current market price for heavy duty clear trash bags ( i.e., high resistant to punctures and tears; handles dry and wet loads up to 75 pounds), including shipping and handling, and

sales tax. 79

, 80



## Exhibit 4

- 8 shows the annual cost

, per facility

, to purch ase containers, by type of facilities and type of wipe s

.

Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 145.

77 

### This assumptions was obtained from the economic background document developed for the proposed rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background

Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. pp. 144

- 148.

78 

### This assumptions was obtained from the economic background document developed for the proposed rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Econ omics Background

Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. pp. 145

- 146.

79 

### C urrent market price for heavy duty clear trash bags (i.e., box of 125 bags at $32.95) was obtained at: http://www.2kstore.com/gragr/jwod/nsn2.htm , last accessed on October 26, 2011.

80 

### Container costs were estimated using the following equation: [R etail price] + [8% shipping and handling cost] + [6% sales tax] = [Retail price] x 1.14 . This equation was obtained from the economic background document originally developed for the proposed rule.

### 54 

## Exhibit 4

- 8

Annual Cost

, per Facility

, to Purchase Containers, 2011 Dollars

Type of

Facilities Reusable Wipes a , b Disposable Wipes a , b

LQG s $27 $25

SQG s $5 $3

Handling Facilities Not Applicable Not Applicable

a Cost per Facility = [50% of the Total Annual Number of Containers per Facility (containers/facility)] x [$0.30/container]. The “total annual number of containers per facility” is 167 for LQGs

- disposable wipes, 22 for

SQGs

- disposable wipes, 180 for LQGs

- reusab le wipes, and 31 for SQGs

- reusable wipes.

b Costs in the exhibit are rounded to the nearest whole number.



## 4.3.4. Purchase of Labels

To be eligible for the conditional exclusions, solvent

- contaminated wipes must be accumulated, stored, and transported in non

- leaking, closed containers that are labeled “Excluded Solvent

Contaminated Wipes.” Therefore, under the final rule, generators will need to purchase labels

for the closed containers.

To estimate the costs associated with the purchase of labels, the a nalysis employs the following assumptions:

• For solvent

- contaminated reusable wipes, each LQG facility will need a total of 180 containers per year; each SQG facility will need a total of 31 containers per year. 81



## • For solvent

- contaminated disposable wipes , each LQG facility will need a total of 167 containers per year; each SQG facility will need a total of 22 containers per year. 82



## • Generators will affix one label to each container (i.e., plastic bag). 83



## • The cost of one pre

- printed vinyl adhesive label is $0.84 (2011 dollars). This cost is based on the current market price of pre

- printed vinyl adhesive labels, including shipping

and handling, and sales tax. 84

, 85

81 

### Refer to Section 4. 3.3 of this document for informatio n on the derivation of the total annual number of

containers needed for solvent

- contaminated reusable wipes.

82 

### Refer to Section 4. 3.3 of this document for information on the derivation of the total annual number of

containers needed for solvent

- contaminat ed disposable wipes.

83 

### This assumptions was obtained from the economic background document developed for the proposed rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background

Document

- Estimate of Nationa l Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 149.

84 

### C urrent market price for one pre

- printed 6 x 6 vinyl adhesive label (i.e., package of 25 labels at $18.50)

was obtaine d at: http://www.labsafety.com/lab

- safety

- supply

- nonhazardous

- waste

- labels

- vinyl

- 6h

- x

- 6w

- pkg

- of

25_s_131535V/#main ProductBottom , la st accessed on October 16, 2011.

85 

### Label costs were estimated using the following equation: [Retail price] + [8% shipping and handling cost] + [6% sales tax] . This equation was obtained from the economic background document originally d eveloped for the proposed rule. U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National

### 55 

## Exhibit 4

- 9 shows the annual cost

, per facility

, to purchase labels, by type of facilit ies and type of wipe s

.

Exhibit 4

- 9

Annual Cost

, per Facility

, to Purchase Labels, 2011 Dollars

Type of

Facilities Reusable Wipes a, b Disposable Wipes a, b

LQG s $152 $140

SQG s $26 $19

Handling Facilities Not Applicable Not Applicable

a Cost per Facility = [Total Annual Number of Containers per Facility (containers/facility)] x [1 label/container] x [$0.84/label]. The “total annual number of containers per facility” is 167 for LQGs

- disposable wipes, 22 for

SQGs

- disposable wipes, 180 for LQGs

- reusable wipes, and 31 for SQGs

- reusable wipes.

b Costs in the exhibit are rounded to the nearest whole number.



## 4.3.5. Affixing Labels to Containers

To be eligible for the conditional exclusions, solvent

- contaminated wipes must be accumulated,
stored, and transported in non

- leaking, closed containers that are labeled “Excluded Solvent

Contaminated Wipes.” Therefore, under the final rule, generators will need to affix labels to

closed containers.

To estimate the costs associated with affixing labels to co ntainers, the analysis employs the following assumptions:

• For solvent

- contaminated reusable wipes, each LQG facility will need a total of 180 containers per year; each SQG facility will need a total of 31 containers per year. 86



## • For solvent

- contaminated disposable wipes , each LQG facility will need a total of 167 containers per year; each SQG facility will need a total of 22 containers per year. 87



## • Generat ors will affix one label to each container (i.e., plastic bag). 88



## • Each designated person (i.e., janito rial or cleaning level employee ) takes an estimated one minute (or 0.02 hours) to affix a label to a closed container. 89



### Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation

. July 17, 2003. p. 142

.

86 

### Refer to Section 4. 3.3 of this document for information on the derivation of the total annual number of

containers needed for solvent

- contaminated reusable wipes.

87 

### Refer to Section 4. 3.3 of this document for information on the derivation of the total annual number of

containers needed for solvent

- contaminated disposable wipes.

88 

### This assumptions was obtained from the economic background document developed for the proposed
rule, and is ba sed on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background

Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 149.

89 

### Ibid.

### 56 

## • This a ctivity is expected to be conducted by a janitorial/cleaning

- level employee

, making $17.59 per hour (2011 dollars).

Exhibit 4

- 10 shows the annual cost

, per facility

, to affix labels to containers, by type of facilities and type of wipe s

.

Exhibit 4

- 10

Annual Cost

, per Facility

, to Affix Labels to Containers, 2011 Dollars

Type of

Facilities Reusable Wipes a, b Disposable Wipes a, b

LQG s $63 $59

SQG s $11 $8

Handling Facilities Not Applicable Not Applicable

a Cost per Facility = [Total Annual Number of Containers per Facility (containers/facility)] x [1 label/container] x [0.02 hours/container] x [$17.59/hour]. The “total annual number of containers per facility” is 167 for LQGs

disposable wipes, 22 for SQGs

- disposable wipes, 180 for LQGs

- reusable wipes, and 31 for SQGs

- reusable wipes.

b Costs in the exhibit are rounded to the nearest whole number.



## 4.3.6. Removing “Free Liquids” from Containers

Under the final rule, solvent

- contaminated reusable wipes must contain “no free liquids” at the point of being sent for cleaning on

- site or at the point of being transported off

- site for cleaning. Similarly, solvent

- contaminated disposable wipes must contain “no free liquids” at the point of being transported for disposal

. Therefore, generators of solvent

- contaminated reusable and disposable wipes must remove (i.e., decant) “free liquids” from containers in o rder for their wipes to be eligible for the conditional exclusions under the final rule. 90

, 91



## This analysis assumes that generators and handlers in states that have exclusions for solvent

contaminated reusable wipes are already in compliance with the “no f ree liquids” standard. Therefore, there are no incremental costs associated with the removal of “free liquids” from

containers under the final rule for solvent

- contaminated reusable wipes

. In contrast, there are

costs associated with the removal of “free liquids” from containers with solvent

- contaminated disposable wipes.

90 

### This analysis assumes that facilities will decant containers with solvent

- contaminated wipes in order to capture excess solvents. The analysis also a ssumes that facilities that use solve nt extraction technologies (e.g., centrifugation) may re use the captured solvent, thereby realizing cost savings from avoided solvent extraction costs and avoided purchase of virgin solvent . Note, however, that facilities are assumed to use costlier solvent extraction technologies only to the extent that doing so is economically beneficial (and, therefore, that the costs of such technologies will be offset by associated savings).

91 

### Solvent

- contaminated wipes can compress in transit and solvent can percolate through the wipes and

collect at the bottom of the co ntainer. This means that, while there may not have been “free liquids” in the container at the generator site, some may be generated durin g transportation. However, if generators comply with the final rule as written, no “free liquids” would be received at the handling facilities. Therefore, the analysis does not estimate incremental costs to handling facilities for removal and management of “free liquids.”

### 57 

## To estimate costs associated with the removal of “free liquids” from containers, the analysis employs the following assumptions:

• On average, each LQG facility generates about 98,256 solvent

- contaminated disposable wipes with “free liquids” per year; each SQG facility generates about 14,475 solvent

contaminated disposable wipes with “free liquids” per year. 92 

## EPA estimates that, on average, each 34

- gallon plastic bag has a loading capa city of 1,144 solvent

contaminated disposable wipes. 93 

## To estimate the number of containers needed to comply with this requirement , the analysis takes the annual number of solvent

contaminated disposable wipes with “free liquids” per facility and divide d i t by the loading capacity of a 34

- gallon plastic bag . Based on this calculation, EPA estimates that each LQG facility will need 86 containers with “free liquids” per year (i.e., 98,256 wipes with “free liquids” per year / 1,144 wipes per container); each SQG facility will have 13

containers with “free liquids” per year (i.e., 14,475 wipes with “free liquids” per year / 1,144 wipes per container).

• Each designated person (i.e., janitorial or cleaning

- level employee) is estimated to take

about five minutes ( or 0.08 hour s ) to remov e “free liquids” from a container

. 94



## • This a ctivity is expected to be conducted by a janitorial/cleaning

- level employee

, making $17.59 per hour (2011 dollars)

.

Exhibit 4

- 11 shows the annual cost

, per facility , to remov e “free liquids” from containers, by type

of facilities and type of wipe s

.

92 

### These estimates are based on the annual number of solvent

- contaminated disposable wipes in

Exhi bit 3

- 2 and the number of generators of solvent

- contaminated disposable wipes in Exhibit 3

- 1 of this document. The analysis assumes that 100 percent of solvent

- contaminated wipes generated by printer fac ilities will have “free liquids ” and that 50 percent of solvent

- contaminated wipes generated by non

- printer facil ities will have “free liquids.” Note that, due to rounding error, the reader may not obtain the same estimates provided in this bullet.

93 

### This assumptions was obtained from the economic backgro und document developed for the proposed rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background

Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RC RA Hazardous Waste Regulation . July 17, 2003. p. 145.

94 

### This assumption was obtained from the economic background document developed for the proposed rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Backgro und

Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 152.

### 58 

## Exhibit 4

- 11

Annual Cost

, per Facility

, to Remov e “Free Liquids” from Containers, 2011 Dollars

Type of

Facilities Reusable Wipes Disposable Wipes a, b

LQG s Not Applicable $121

SQG s Not Applicable $18

Handling Facilities Not Applicable Not Applicable

a Cost per Facility = [Annual Number of Containers with “Free Liquids” per Facility (containers/facility)] x [0.08 hours/container] x [$17.59/hour]. The “annual number of containers with ‘free liquids’ per facility” is 86 for LQGs

and 13 for SQGs.

b Costs in the exhibit are rounded to the nearest whole number.



## 4.3.7. Management of “Free Liquids” Removed From Containers

Under the final rule, any liquids removed from solvent

- contaminated wipes must be managed according to the applicable hazardous waste regulations

. This translates to cost savings f rom avoiding future purchases of virgin solvents if captured spent solvent “free liquids” are recycled

. Th e analysis assum es that generators and handlers in states that have exclusions for solvent

contaminated reusable wipes are already in compliance with the “no free liquids” standard. Therefore, there are no cost savings associated with the management of “free liquids” rem oved

from containers under the final rule for solvent

- contaminated reusable wipes. In contrast, there are cost savings associated with the management of “free liquids” from containers with solvent

contaminated disposable wipes.

To estimate the cost saving s to manag e “free liquids” removed from containers, the analysis employs the following assumptions:

• On average, each LQG facility will use about 86 containers of solvent

- contaminated disposable wipes with “free liquids” per year; each SQG facility will use about 13

containers of solvent

- contaminated disposable wipes with “free liquids” per year. 95



## • On average, a LQG facility removes approximately 0.46 gallons of “free liquids” from

each 34

- gallon container of solvent

- contaminated wipes; a SQG facilit y removes approximately 0.96 gallons of “free liquids” from each 34

- gallon container of solvent

contaminated wipes. 96



## • When considering the method to be used for managing “free liquids” removed from containers, generators are expected to opt for the least costly behavior, which is the use of solvent recovery.

95 

### Refer to Section 4.3.6 of this document for information on the derivation of the tot al annual number of

containers of solvent

- contaminated disposable wipes with “free liquids

. ”

96 

### These estimates are based on the annual number of containers of solvent

- contaminated disposable wipes with “free liquids

. ” The analysis assumes that, on averag e, printer facilities remove 3.09 gallons of “free liquids” from a 34

- gallon container of s olvent

- contaminated wipes ; non

- printer facilities remove 0.31 gallons of “free liquids” from a 34

- gallon container of s olvent

- contaminated wipes . Note that, due to rounding error, the reader may not obtain the same estimates provided in this bullet.

### 59 

## • The net cost to manag e “free liquids” as hazardous waste through solvent recovery is estimated to be ($1.88) per gallon (2011 dollars). The economic background document

derived this estimate by subtracting the unit price for solvent recovery from the unit price for virgin solvent in order to reflect the resale (reuse) net value of recycled solvent. The

per

- gallon cost estimate in the economic background document for the proposed rule 97



## has been updated to 2011 dollars using GDP deflators developed by the U.S. Department of Commerce. 98



## Exhibit 4

- 12 shows the annual cost

, per facility

, to manage “free liquids” from containers, by type

of facilities and type of wipe s

.

Exhibit 4

- 12

Annual Cost

, per Facility

, to Manag e “Free Liquids” Removed from Containers, 2011 Dollars

Type of

Facilities Reusable Wipes Disposable Wipes a, b, c

LQG s Not Applicable ($75)

SQG s Not Applicable ($23)

Handling Facilities Not Applicable Not Applicable

a Cost per Facility = [Annual Number of Containers with “Free Liquids” per Facility (containers/facility)] x [Gallons of “Free Liquids” Removed from a 34

- Gallon Container (gallons/container)] x [($1.88)/gallon]. The

“annual number of containers with ‘free liquids’ per facility” is 87 for LQGs and 13 for SQGs. The “gallons of ‘free liquids’ removed from a 34

- gallon container” is 0.46 for LQGs and 0.96 for SQGs.

b Costs in the exhibit are rounded to the nearest whole number.

c Values in parentheses denote cost savings.



## 4.3.8. Avoided Hazardous Waste Manifest Costs

Under the final rule, solvent

- contaminated reusable and disposable wipes that meet the specified conditions will enter the non

- hazardous waste stream and thus, will not be subject to the hazardous waste manifest requirements. These avoided costs (i.e., cost savings) will benefit all parties involved in the hazardous waste manifest process, including generators and

handlers of solvent

- contaminated wipes.

This analysis assum es that generators and handlers in s tate s that currently have exclusions for

solvent

- contaminated reusable wipes are not subject to the hazardous waste manifest requirements. Therefore, there are no cost savings associated with hazardous waste manifest requirements for solvent

- contaminated reusable wipes

. In contrast, there are cost savings associated with hazardous waste manifest requirements for solvent

- contaminated disposable wipes.

97 

### U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation

. July 17, 2003. p. 153.

98 

### U.S. Department of Commerce, Bureau of Economic Analysis

. “ Table 1.1.9. Implicit Price Deflators for

Gross Domestic Product

. ” Available online at: http://www.bea.gov/national/nipaweb/TableView.asp?SelectedTable=13&Freq=Qtr&FirstYear=2006&LastYear=2008

, last accessed on November 6 , 2011. Year 2003, Quarter II = 93.815 and Year 2011 , Quarter III = 113.823

.

### 60 

## To estimate the avoided hazardous waste ma nifest costs, the analysis employs the following assumptions:

• On average , each LQG facility will fill about 167 containers with solvent

- contaminated disposable wipes each year; each SQG facility will fill about 22 containers with solvent

contaminated disp osable wipes each year. 99



## • The on

- site RCRA accumulation time period for containers is 90 days (i.e., three months) for a LQG facility and 180 days (i.e., six months) for a SQG facility. 100



## • The average n umber of containers that can be transported on a truck is 40. 101



## • EPA estimates that there will be about 998 hazardous waste management facilities that manage solvent

- contaminated disposable wipes in states that are expected to adopt the

final rule

.

• T he cost associated with a hazar dous waste manifest is $ 143 for a LQG facility, $137 for a SQG facility, and $44 for a handing facility (2011 dollars)

. 102 

## These costs are based on total unit costs for the manifest process that EPA applied in a proposed rulemaking

for the RCRA hazardous wa ste manifest system in 2001

. 103

, 104 

## The unit labor costs have been updated to 2011 dollars using employment cost data developed by the

Bureau of Labor Statistics. 105



## Exhibit 4

- 13 shows the annual avoided hazardous waste manifest cost

, per facility, by type of

facilities and type of wipe s

.

99 

### Refer to Section 4. 3.3 of this document for information on the derivation of the total annual number of

containers for solvent

- contaminated disposable wipes.

100 

### This assumptions was obtained from the economic background document developed for the proposed
rule, and is based on the accumulation time limits at 40 CFR 262.34. U.S. Environmental Protection Agency. Economics Background Document

- Estimate of Nation al Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 150.

101 

### This assumptions was obtained from the economic background document developed for the proposed
rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background

Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 150.

102 

### The se costs include the following components: (1) preparing the manifest; (2) transmitting the manifest between generator, transporter, and management facility; (3) manifest recordkeeping; (4) obtaining manifest forms; (5) submitting copies of final signed m anifests to state agencies; and (6) employee training.

103 

### U.S. Environmental Protection Agency. Hazardous Waste Manifest Cost Benefit Analysis . October

2000. Available at: http://www.epa.gov/osw/hazard/transportation/manifest/pdf/cba

- rprt.pdf , last accessed on
November 11, 2011.

104 

### This data source also was used in the development of the economic background document originally developed for the proposed rule.

105 

### Bureau of Labor Statistics. Employment Cost Index

- Historical Listing, June 2011 ; "Table 5. Employment Cost Index for total compensation, for private industry workers, by occupation and industry; Continuous occupational and industry series (not seasonally adj usted)." Available online at: http://www.bls.gov/web/eci/ecicois.pdf , last accessed on October 26, 2011. Private Industry Workers, All Workers, September 2010=112.2 and June 2011=114.3.

### 61 

## Exhibit 4

- 13 Annual Avoided Hazardous Waste Manifest Cost per Facility, 2011 Dollars

Type of

Facilities Reusable Wipes Disposable Wipes b, c, d, e

LQG s Not Applicable ($597)

SQG s Not Applicable ($77)

Handling Facility a Not Applicable ($208)

a For solvent

- contaminated disposable wipes , handling facilities include hazardous waste management

facilities

.

b Cost per LQG or SQG Facility = [Total Annual Number of Containers per Facility (containers/facility)] / [12 months/year] x [On

- Site RCRA Accumulation Time Period (months)] / [40 containers/truckload] x [Annual Conversion Factor] x [Manifest Cost]. The “total annual number of containers per facility” is 167 for LQGs and

22 for SQGs

- disposable wipes. The “on

- site RCRA accumulation time period” is 3 months for LQGs and 6

months for SQGs. The “annual conversion factor” is 4 for LQGs and 2 for SQGs. The “manifes t cost” is $143 for LQGs and $137 for SQGs.

c Cost per Handling Facility = ([Number of LQG Manifests] + [Number of SQG Manifests]) * [$44/manifest] / [998 Handling Facilities]

where:

[Number of LQG Manifests] = [167 containers/facility] / [12 months/year] x [3 months] / [40 containers/truckload] x [4 months/year].

[Number of SQG Manifests] = [22 containers/facility] / [12 months/year] x [6 months] / [40 containers/truckload] x [2 mon ths/year].

d Costs in the exhibit are rounded to the nearest whole number.

e Values in parentheses denote cost savings.



## 4.3.9. Avoided Disposal Costs

Under the final rule, solvent

- contaminated disposable wipes that meet the specified conditions

will enter the non

- hazardous waste stream. As a result, generators will be able to send their

solvent

- contaminated disposable wipes to municipal solid waste landfill s and solid waste combustors. Disposing of the s olvent

- contaminated wipes at non

- hazardous waste management facilities, rather than hazardous waste management facilities, will result in cost savings to generators.

To estimate the avoided disposal costs, the analysis employs the following assumptions:

• On average, each LQG facility generates about 191,008 solvent

- contaminated disposable wipes per year; each SQG facility generates about 25,5 87 solvent

contaminated disposable wipes per year. 106



## • On average , each LQG facility will fill about 167 containers with solvent

- contaminated disposable wipes each year; each SQG facility will fill about 22 containers with solvent

contaminated disposable wipes each year. 107

106 

### These estim ates are based on the annual number of solvent

- contaminated disposable wipes in

Exhibit 3

- 2 and the number of generators of solvent

- contaminated disposable wipes in Exhibit 3

- 1 of this document. Note that, due to rounding error, the reader may not obtain the same estimates provided in this bullet.

107 

### Refer to Section 4. 3.3 of this document for information on the derivation of the total annual number of

containers for solvent

- contaminated disposable wipes.

### 62 

## • Pursuant to 40 CFR 264.314, the placement of hazardous waste containing “free liquids” (whether or not sorbents have been added) in any landfill is prohibited. Without the “no free liquids” requirement in effect nationwide, there is no "guarantee" that any single

container of solvent

- contaminated disposable wipes contains "no free liquids.”

Therefore , under the regulatory baseline, solvent

- contaminated disposable wipes are not accepted at hazardous waste landfills because of the risk that the container also may contain "free liquids" that have percolated out of the wipes during transport to the landfill. All generators of solvent

- contaminated disposable wipes send their wipes to hazardous

waste incineration facilities. 108



## • U nder the final rule, 50 percent of solve nt

- contaminated disposable wipes will be sent to municipal solid waste landfills and the other 50 percent of solvent

- contaminated disposable wipes will be sent to solid waste combustors. 109



## • On average, the weight of a solvent

- contaminated disposable wipe is 0.054 pounds (i.e., 33,333 wipes per ton). 110



## • On average, the residual of the incineration process (i.e., incineration ash) is 10 percent of the weight. 111



## • Disposal costs are estimated as follows:

Type of Disposal s Estimated Cost (2011 Dollars)

Hazardous waste incineration a 

### $181 per container

Incineration ash at a hazardous waste landfill a 

### $485 per ton

Municipal solid waste landfill b 

### $4 per container

Solid waste combust ion b 

### $6 per container

Incineration ash at a municipal solid waste landfill b 

### $37 per ton

a Cost estimate was obtained from the economic background document originally developed for the proposed rule 112 and updated to 2011 dollars using GDP deflators developed by the U.S. Department of Commerce. 113

b Cost estimate was derived using data in Waste Business Journal’s “Directory & Atlas of Non

- Hazardous Waste Sites 2007.” Detailed information on these costs is presented in Exhibit 4

- 14

.

108 

### U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation

. July 17, 2003. p. 156.

109 

### Based on professional judgment.

110 

### Ibid.

111 

### Ibid.

112 

### Ibid.

113 

### U.S. Departmen t of Commerce, Bureau of Economic Analysis

. “ Table 1.1.9. Implicit Price Deflators for

Gross Domestic Product

. ” Available online at: http://www.bea.gov/national/nipaweb/TableView.asp?SelectedTable=13&Freq=Qtr&FirstYear=2006&LastYear=2008

, last accessed on November 6 , 2011. Year 2003, Quarter II = 93.815 and Year 2011 , Quarter III = 113.823

.

### 63 

## Disposal costs presented in the above e xhibit for municipal solid waste landfills and solid waste combustors are based on tipping fees for solid waste m anaged in non

- hazardous waste facilities

in the U.S. Exhibit 4

- 14 shows state tipping fees, as well as the estimated disposal costs at the

national level.

### 64 

## Exhibit 4

- 14 Tippin g Fees for Solid Waste Managed in

Non

- Hazardous Waste Facilities in the United States , 2011 Dollars a

State s Municipal Solid Waste Landfill b Solid Waste Combustion b

Number of

Facilities Minimum

Cost ($/ton) Maximum

Cost ($/ton) Average

Cost ($/ton) Number of

Facilities Minimum

Cost ($/ton) Maximum

Cost ($/ton) Average

Cost ($/ton)

Alabama 33 $9.58 $47.88 $31.40 1 $42.45 $42.45 $42.45

Alaska 18 $15.00 $191.52 $54.83 3 $148.96 $152.48 $150.13

Arizona 42 $10.64 $69.43 $34.54

Arkansas 34 $1.44 $53.20 $28.76 1 $26.60 $26.60 $26.60

California 136 $4.26 $95.76 $42.45 6 $9.04 $77.10 $46.68

Colorado 53 $6.38 $95.76 $23.36 1 $26.60 $26.60 $26.60

Connecticut 13 $31.92 $170.24 $83.02 7 $27.66 $80.86 $64.14

Delaware 4 $65.44 $65.44 $65.44

Florida 55 $14.62 $90.44 $47.05 13 $29.79 $148.96 $70.55

Georgia 76 $7.98 $69.16 $34.52 1 $63.84 $63.84 $63.84

Hawaii 8 $37.24 $86.47 $54.96 1 $86.47 $86.47 $86.47

Idaho 19 $4.79 $65.33 $25.36

Illinois 48 $21.28 $82.99 $40.34

Indiana 37 $14.36 $53.20 $34.28 1 $28.73 $28.73 $28.73

Iowa 64 $10.37 $63.84 $36.18

Kansas 61 $4.26 $106.40 $30.55

Kentucky 29 $16.12 $50.58 $32.05

Louisiana 21 $15.96 $47.88 $28.00 1 $19.15 $19.15 $19.15

Maine 8 $50.54 $90.44 $76.81 4 $60.61 $106.40 $85.38

Maryland 22 $31.92 $85.12 $55.71 3 $44.69 $71.82 $54.44

Massachusetts 24 $0.53 $117.15 $72.22 7 $53.20 $96.82 $77.82

Michigan 51 $15.96 $77.67 $39.80 3 $55.86 $93.48 $69.26

Minnesota 42 $11.70 $95.76 $50.68 8 $42.29 $74.48 $60.18

Mississippi 26 $9.58 $44.75 $26.52

Missouri 25 $17.56 $59.58 $38.12

Montana 22 $12.24 $88.31 $38.23 1 $63.84 $63.84 $63.84

Nebraska 22 $12.77 $46.82 $32.35

Nevada 13 $10.96 $42.56 $20.22

New Hampshire 12 $2.13 $91.30 $57.89 3 $69.16 $92.57 $82.28

New Jersey 15 $46.14 $101.35 $75.22 5 $64.90 $92.45 $74.56

New Mexico 29 $3.19 $38.30 $20.80

New York 34 $25.54 $106.40 $62.64 10 $23.41 $106.40 $69.46

North Carolina 55 $24.47 $105.34 $40.25 1 $48.94 $48.94 $48.94

North Dakota 21 $9.58 $39.90 $27.94

## Exhibit 4

- 14 (continued) Tippin g Fees for Solid Waste Managed in

Non

- Hazardous Waste Facilities in the United States , 2011 Dollars a



### 65 State s Municipal Solid Waste Landfill b Solid Waste Combustion b

Number of

Facilities Minimum

Cost ($/ton) Maximum

Cost ($/ton) Average

Cost ($/ton) Number of

Facilities Minimum

Cost ($/ton) Maximum

Cost ($/ton) Average

Cost ($/ton)

Ohio 43 $17.56 $63.84 $36.60 1 $25.54 $25.54 $25.54

Oklahoma 40 $14.36 $47.88 $23.90 1 $58.52 $58.52 $58.52

Oregon 37 $9.58 $106.40 $31.61 2 $46.82 $71.77 $59.29

Pennsylvania 47 $37.24 $110.66 $61.38 7 $21.28 $77.14 $54.42

Rhode Island 4 $28.73 $69.16 $56.39

South Carolina 30 $12.77 $53.20 $35.70 1 $63.31 $63.31 $63.31

South Dakota 14 $6.38 $47.88 $32.57

Tennessee 36 $19.58 $51.07 $34.26 2 $27.66 $48.94 $38.30

Texas 173 $4.72 $133.00 $27.71 2 $106.40 $212.80 $159.60

Utah 26 $2.66 $68.10 $24.06 1 $26.60 $26.60 $26.60

Vermont 11 $25.54 $212.80 $93.89 1 $45.57 $45.57 $45.57

Virginia 65 $15.96 $63.84 $43.37 6 $35.11 $58.52 $43.10

Washington 25 $13.57 $138.32 $56.49 4 $95.92 $127.68 $110.39

West Virginia 19 $29.85 $74.48 $45.63

Wisconsin 40 $10.64 $106.40 $41.48 2 $36.71 $58.52 $47.61

Wyoming 36 $6.38 $58.52 $29.22

Total 1,818 111

Median per ton $37.00 Median per ton $59.00

Median per container $4.00 Median per container $6.00

a Tipping fee data were obtained from the following data source: Waste Business Journal’s “Directory & Atlas of Non

- Hazardous Waste Sites 2007.

b 2007 cost updated to 2011 dollars using the following data source: U.S. Department of Commerce, Bureau of Economic Analysis. “Ta ble 1.1.9. Implicit Price Deflators for Gross Domestic Product.” Available online at: http://www.bea.gov/national/nipaweb/Table View.asp?SelectedTable=13&Freq=Qtr&FirstYear=2006&LastYear=2008,
last accessed on November 16, 2011. Year 2007, Quarter IV = 106.958 and Year 2011, Quarter III = 113.823.

### 66 

## Exhibit 4

- 15 shows the annual avoided disposal cost per facility, by type of facilities and type of wipe s

.

Exhibit 4

- 15 Annual Avoided Disposal Cost per Facility, 2011 Dollars

Type of

Facilities Reusable Wipes Disposable Wipes a, b, c

LQG s Not Applicable ($ 29,639 )

SQG s Not Applicable ($3,970 )

Handling Facilities Not Applicable Not Applicable

a Cost per Facility = ([Cost per Facility for Hazardous Waste Incineration] + [Cost per Facility for Disposal of Incineration Ash at a Hazardous Waste Landfill])

– ([Cost per Facility for Disposal at Municipal Solid Waste Landfill] + [Cost per Facility for Solid Waste Combustion] + [Cost per Facility for Disposal of Incineration Ash at a Muni cipal Solid Waste Landfill])

where:

Cost per Facility for Hazardous Waste Incineration = [Total Annual Number of Containers per Facility (containers/facility)] x [$181/container]. The “total annual number of containers per facility” is 167 for LQGs and 22

for SQGs

- disposable wipes.

Cost per Facility for Disposal of Incineration Ash at a Hazardous Waste Landfill = [Annual Number of Wipes per Facility] / [33,333 wipes/ton] x [10% Incineration Ash Residual] x [$485/ton]. The “annual number of wipes per facility

is 191,008 for LQGs and 25,587 for SQGs.

Cost per Facility for Disposal at Municipal Solid Waste Landfill = [50% of Total Annual Number of Containers per Facility (containers/facility)] x [$4/container]. The “total annual number of containers per facility” is 167 for LQGs and

22 for SQGs

- disposable wipes.

Cost per Facility for Solid Waste Combustion = [50% of Total Annual Number of Containers per Facility (containers/facility)] x [$6/container]. The “total annual number of containers per facility” is 167 for LQGs and 22 for

SQGs

- disposable wipes.

Cost per Facility for Disposal of Incineration Ash at a Municipal Solid Waste Landfill = [50% of Annual Number of Wipes per Facility] / [33,333 wipes/ton] x [10% Incineration Ash Residual] x [$37/ton]. The “annual number of wipes per facility” is 191,008 for LQGs and 25,587 for SQGs.

b Costs in the exhibit are rounded to the nearest whole number.

c Values in parentheses denote cost savings.



## 4.3.10. Complying with Recordkeeping Requirements under the Final Rule

Under the final rule, g enerators of solvent

- contaminated wipes must maintain at their site

documentation to demonstrate that they are managing excluded solvent

- contaminated wipes according to the final rule requirements.

• For solvent

- contaminated reusable wipes , documentation must include: (1) name and address of the laundry or dry cleaner that is receiving the solvent

- contaminated wipes

, (2) documentation that the 180

- day accumulation time limit in 40 CFR 261.4(a)(26)(ii) is being met, and ( 3 ) description of t he process the generator is using to ensure the

solvent

- contaminated wipes contain “no free liquids” at the point of being laundered or dry

- cleaned on

- site or at the point of being transported off

- site for laundering or dry

cleaning.

• For solvent

- contamina ted disposable wipes

, documentation must include: (1) name and address of the landfill or combustor that is receiving the solvent

- contaminated wipes, (2) documentation that the 180 day accumulation time limit in 40 CFR 261.4(b)(18)(ii) is being met, and (3) description of the process the generator is using to ensure solvent

contaminated wipes contain “no free liquids” at the point of being transported for disposal.

### 67 

## To estimate the costs associated with the above recordkeeping requirements, the analysis

e mploys the following assumptions:

• Each designated person (i.e., a supervisory

- level employee) is estimated to take about 15 minutes (or 0.25 hours) per year to document that the facility is managing excluded

solvent

- contaminated wipes in accordance with t he final rule.

• This activity is expected to be conducted by a supervisory

- level employee

, making $33.36 per hour (2011 dollars).

Exhibit 4

- 16 shows the annual cost per facility for complying with the recordkeeping requirements under the final rule, by type of facilities and type of wipe s

.

Exhibit 4

- 16

Annual Costs

, per Facility

, to Comply with the Recordkeeping Requirements under the Final Rule, 2011 Dollars

Type of

Facilities Reusable Wipes a , b Disposable Wipes a , b

LQG s $8 $8

SQG s $8 $8

Handling Facilities Not Applicable Not Applicable

a Cost per Facility = [0.25 hours/generator] x [$33.36/hour].

b Costs in the exhibit are rounded to the nearest whole number.



## 4.3.11. Demonstrating Compliance with Final Rule Conditions

Generators and handlers of solvent

- contaminated wipes will need to demonstrate compliance with the final rule conditions to inspectors from regulating agencies (i.e., s tate inspectors, or EPA Regional inspectors):

• Generators of solvent

- contaminated reusable wipes. The analysis assumes that generators in s tate s that have exclusion s for solvent

- contaminated reusable wipes are already in compliance with applicable requirements. The only additional cost associated

with this section is to demonstrat e co mpliance with the recordkeeping requirements of

the final rule

.

• Generators of solvent

- contaminated disposable wipes. T he analysis assumes that any

costs to demonstrat e compliance with the final rule conditions and recordkeeping requirements are offset by the savings in demonstrating compliance with applicable hazardous waste requirements.

• Handlers of solvent

- contaminated wipes. Handling facilities are subject to inspe ctions and evaluations under the majority of statutory and regulatory programs (e.g., RCRA Subtitle C and D, as applicable; Clean Air Act; Clean Water Act; OSHA; Toxic Substances Control Act (TSCA)). Given that these inspections and evaluations will

### 68 

## conti nue to take place under the final rule, this analysis assumes that the re are no
additional costs to handl ing facilities under this section

.

To estimate the costs to generators of solvent

- contaminated reusable wipes for demonstrating compliance with the fi nal rule conditions, the analysis employs the following assumptions:

• In s tates that are expected to adopt the final rule, there are approximately 397 LQGs and
62,081 SQGs that use solvent

- contaminated reusable wipes.

• On average, 6 LQGs and 118 SQGs will be inspected by a regulatory agency each

year. 114



## • Each designated person (i.e., a supervisory

- level employee) is estimated to take about 5 minutes (or 0.08 hours) to provid e evidence that shows compliance with the recordkeeping requirements of the final rule.

• This activity is expected to be conducted by a supervisory

- level employee

, making $33.36 per hour (2011 dollars).

Exhibit 4

- 17 shows the annual cost

, per facility

, to demonstrate compliance with the recordkeeping requirements , by type of facilities and type of wipe s

.

Exhibit 4

- 17

Annual Costs

, per Facility

, to Demonstrate Compliance with the Recordkeeping Requirements , 2011 Dollars

Type of

Facilities Reusable Wipes a , b Disposable Wipes

LQG s $3 Not Applicable

SQG s $3 Not Applicable

Handling Facilities Not Applicable Not Applicable

a Cost per Facility = [0.08 hours/generator] x [$33.36/hour].

b Costs in the exhibit are rounded to the nearest whole number.

114 

### The analysis assumes that 1 5 percent of generators in the “chemical and allied products” economic sub

sector and 0.06 percent of generators in all other economic sub

- sectors are subject to inspections each year. U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 167.

### 69 

## 4.3.12. Avoided RCRA Information Collection Requirement Costs for SQGs that May Become CESQGs

Under the final rule, solvent

- contaminated reusable and disposable wipes that meet the specified conditions will enter the non

- hazardous waste stream and thus, will not be counted towards generator status determination (e.g., L QG, SQG). As a result, some SQGs may experience a change in generator status and become CESQGs. 115 

## They are exempt from the full hazardous waste regulations that apply to LQGs and SQGs, including information collection requirements. The avoided RCRA info rmation requirements will result in cost savings to the

SQGs that become CESQGs.

This analysis assumes that in states that have exclusion s for solvent

- contaminated reusable wipes, these wipes have already entered into the non

- hazardous waste stream. As a result, SQGs that become CESQGs are not subject to the full hazardous waste regulations. Therefore,

for solvent

- contaminated reusable wipes, there are no cost savings associated with RCRA information collection requir ements for SQGs that become CESQGs under the final rule.

However

, there are cost savings associated with RCRA information collection requirements for

solvent

- contaminated disposable wipes.

To estimate the avoided RCRA information collection requirement c osts, the analysis employs the following assumptions:

• In s tates that are expected to adopt the final rule, there are about 35 LQGs and 5,398 SQGs that generate solvent

- contaminated disposable wipes (see Exhibit 3

- 1)

.

• None of the LQGs will experience a ch ange in generator status under the final rule. 116



## • 1.7 percent or approximately 92 SQGs are expected (or estimated) to become CESQG

under the final rule. 117



## • The annual costs associated with avoided RCRA information collection requirements are estimated to be $6,663 (2011 dollars) per generator. The cost in the economic background document originally developed for the proposed rule 118 

## has been updated to

2011 do llars using employment cost data developed by the Bureau of Labor Statistics. 119

115 

### CESQGs are facilities that, in a single calendar month, generate 100 kilograms (220 pounds) or less of

hazardou s waste, or 1 kilogram (2.2 pounds) or less of acute hazardous waste.

116 

### This assumptions was obtained from the economic background document developed for the proposed rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Ec onomics Background

Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 168.

117 

### Ibid.

118 

### Ibid.

119 

### Bureau of Labor Statistics. Employment Cost Index

- Historical Listing, June 2011

, "Table 5. Employment Cost Index for total compensation, for private industry workers, by occupation and industry; Continuous occupational and industry series (not seasonally adjusted), p. 10. Available online at: http://www.bls.gov/web/eci/ecicois.pdf , last accessed on October 26, 2011. Private Industry Workers, All Workers, September 2003=93.2 and June 2011=114.3.

### 70 

## Exhibit 4

- 18 shows the annual cost

, per facility

, to avoid RCRA information collection requirement s, by type of facilities and type of wipe s

.

Exhibit 4

- 18

Annual Cost

, per Facility

, to Avoid RCRA Information Collection Requirements, 2011 Dollars

Type of

Facilities Reusable Wipes Disposable Wipes a

LQG s Not Applicable $0

SQG s Not Applicable ( $6,663 )

Handling Facilities Not Applicable Not Applicable

a Values in parentheses denote cost savings.



## 4.3.13. Avoided State Waste Fees and Taxes

Under the final rule, solvent

- contaminated reusable and disposable wipes that meet the specified conditions will enter the non

- hazardous waste stream. As a result, generators of

solvent

- contaminated wipes will be subject to s tate non

- hazardous waste fees and taxes (as appropriate)

, as opposed to s tate hazardous waste fee s and taxes. The avoided s tate waste fees and taxes will result in cost savings to generators.

This analysis assumes that generators in s tate s that have exclusion s for solvent

- contaminated

reusable wipes are not subject to s tate hazardous waste fees and taxes. Therefore, for solvent

contaminated reusable wipes, there are no cost savings associated with s tate waste fees and

taxes under the final rule. However, there are cost savings associated with s tate waste fees and taxes app lied to solvent

- contaminat ed disposable wipes.

To estimate the avoided s tate waste fees and taxes, the analysis employs the following assumptions:

• On average, each LQG facility generates about 191,008 solvent

- contaminated disposable wipes per year; each SQG facility generates abo ut 25,5 87 solvent

contaminated disposable wipes per year. 120 

## EPA estimates that, on average, the weight

of a solvent

- contaminated disposable wipe is 0.054 pounds (i.e., 33,333 wipes per ton). 121 

## T o estimate the annual tons of wipes per facility , the analysis takes the annual

number of solvent

- contaminated disposable wipes generated per facility and divides it by

the number of solvent

- contaminated disposable wipes per ton . Based on this calculation, EPA estimates that each LQG facility generates about 5 tons of solvent

contaminated disposable wipes each year (i.e., 191,008 wipes per year / 33,333 wipes
per ton ); each SQG facility generates about 0.69 tons of solvent

- contaminated disposable wipes each year (i.e., 25,5 87 wipes per year / 33,333 wip es per ton ).

120 

### These estimates are based on the annual number of s olvent

- contaminated disposable wipes in

Exhibit 3

- 2 and the number of generators of solvent

- contaminated disposable wipes in Exhibit 3

- 1 of this document. Note that, due to rounding error, the reader may not obtain the same estimates provided in this bull et.

121 

### Ibid.

### 71 

## • Pursuant to 40 CFR 264.314, the placement of hazardous waste containing “free liquids” (whether or not sorbents have been added) in any landfill is prohibited. Without the “no free liquids” requirement in effect nationwide, there is no "gu arantee" that any single

container of solvent

- contaminated disposable wipes contains "no free liquids.” Therefore, under the regulatory baseline, solvent

- contaminated disposable wipes are not accepted at hazardous waste landfills because of the risk that the container also may contain "free liquids" that have percolated out of the wipes during transport to the landfill. All generators of solvent

- contaminated disposable wipes send their wipes to hazardous

waste incineration facilities. 122



## • U nder the final ru le, EPA estimates that 50 percent of solvent

- contaminated disposable wipes will be sent to municipal solid waste landfills and the other 50 percent of solvent

contaminated disposable wipes will be sent to solid waste combustors. 123



## • On average, EPA estimates that the residual of the incineration process (i.e., incineration ash) is 10 percent of the weight. 124



## • State waste fees and taxes are estimated as follows:

State Fee/Tax a 

### Estimated Cost per Ton b



### (2011 Dollars)

Generation of hazardous waste $1.18

Management of hazardous waste at incinerator $35

Management of non

- hazardous waste at municipal solid waste landfill $1.98

Management of non

- hazardous waste at solid waste combustor $1.51

a In estimating avoided s tate waste fees and taxes, the analysis does not take into account annual fees to hazardous waste generators that are not based on generated tons. For purposes of the analysis, it is assumed that generators of solvent

contaminated wipes will continue to g enerate other types of hazardous wastes and thus, continue to be subject to the annual hazardous waste generator fee.

b Estimated cost per ton was derived using data on waste fees and taxes for individual s tates. Detailed information on the

derivation of the cost per ton is presented in Appendix B.



## Exhibit 4

- 19 shows the annual cost

, per facility

, to avoid s tate waste fees and taxes, by type of

facilities and type of wipe s

.

122 

### U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation

. July 17, 2003. p. 156.

123 

### Based on professional judgment.

124 

### Ibid.

### 72 

## Exhibit 4

- 19

Annual Cost

, per Facility

, to Avoid State Waste Fees and Taxes, 2011 Dollars

Type of

Facilities Reusable Wipes Disposable Wipes a, b , c

LQG Not Applicable ($178 )

SQG Not Applicable ($24 )

Handling Facilities Not Applicable Not Applicable

a Cost per Facility = ([Fee/Taxes per Facility for Hazardous Waste Generation] + [Fee/Taxes per Facility for Hazardous Waste Incineration])

– ([Fee/Taxes per Facility for Municipal Solid Waste Landfill Disposal] + [Fee/Taxes per Facility for Solid Waste Combustion])

where:

Fee/Taxes per Facility for Hazardous Waste Gener ation = [Tons of Wipes per Facility] [$1.18/ton)]. The “tons of wipes per facility” is 5 for LQGs and 0.69 for SQGs.

Fee/Taxes per Facility for Hazardous Waste Incineration = [Tons of Wipes per Facility] x [$35/ton)]. The “tons of wipes per facility” is 5 for LQGs and 0.69 for SQGs.

Fee/Taxes per Facility for Municipal Solid Waste Landfill Disposal = [50% of Tons of Wipes] x [$1.98/ton)]. The “tons of wipes per facility” is 5 for LQGs and 0.69 for SQGs.

Fee/Taxes per Facility for Solid Waste Combustion = [50% of Tons of Wipes] x [$1.51/ton)]. The “tons of wipes per facility” is 5 for LQGs and 0.69 for SQGs.

b Costs in the exhibit are rounded to the nearest whole number.

c Values in parentheses denote cost savings.

### 73 

# 5. Other Expected Benefits of the Final Rule

The primary benefit of the final rule is the annual savings associated with RCRA regulatory compliance. As reported in Chapter 4, EPA estimates that the final rule will result in net savings of approximately $1 8.0 million per year (2011 dollars), using real discount rates of 7 percent, 3 percent, and 0 percent. In addition , EPA expects that the final rule will res ult in other expected

benefits.

This chapter describes the other expected benefits of the final rul e. Section 5 .1 summarizes the

other annual expected benefits of the final rule . Section 5.2 estimates anticipated pollution prevention and waste minimization benefits of the final rule. Section 5.3 estimates fire safety

benefits of the final rule. Sect ion 5.4 estimates the expected benefit s to industrial laundries by excluding solvent

- contaminated reusable wipes fro m the definition of solid waste

— that is, removing the label of “waste” for these wipes.



## 5.1. Summary of Other Expected Benefits

Exhibit 5

- 1 su mmarizes the annual value of the other benefits of the final rule. EPA evaluated

these benefits over a 10

- year period, using real discount rates of 7 percent, 3 percent, and 0
percent. 125 

## As shown in the exhibit, at all three discount rates, the other expe cted benefits of

the final rule are estimated to be between $ 3.7 million and $ 9.9 million per year (2011 dollars).

125 

### In annualizing the benefits, the analysis uses a procedure consistent with EPA’s guidelines for discounting future costs and benefits. U.S. Environmental Protection Agency. Guidelines for Preparing Economic Analyses , “C hapter 6, Discounting Future Benefits and Costs.” December 17, 2010 . Available at: http://yosemite.epa.gov/ee/epa/eerm.nsf/vwAN/EE

- 0568

- 50.pdf/$file/EE

- 0568

- 5 0.pdf , last accessed on December 8,

2011.

### 74 

## Exhibit 5

- 1

Other Expected Benefits of the Final Rule, 2011 Dollars a , b



### ( A t All Three Discount Rates Used in the Analysis)

Type of Impact s Benefits (2011 Dollars)

Annual Pollution Prevention and Waste Minimization Benefits c $212,358 to $960,593

Annual Fire Safety Benefits d $230

, 922 to $ 2,309, 219

Annual Benefits to Industrial Laundries by excluding solvent

- contaminated reusable wipes from the definition of solid waste e $3,293,366 to $6,586,733

Total Other Annual Expected Benefits f $ 3,736,647 to $ 9,856, 546

a Benefits are evaluated over a 10

- year period.

b Because the value of the expected benefits is the same for each year under evaluation, the annual benefits are the same at al l

three discount rates used in the RIA

.

c Pollution prevention and waste minimization benefits are presented in Exhibit 5

- 2 o f this document.

d Fire safety benefits are presented in Exhibit 5

- 3 of this document.

e Potential benefits to industrial laundries by excluding solvent

- contaminated reusable wipes from the definition of solid waste are presented in Exhibit 5

- 4 of this d ocument.

f Total Other Expected Benefits = [Annual Pollution Prevention and Waste Minimization Benefits] + [Annual Fire Safety Benefits] + [Annual Benefits to Industrial Laundries by excluding solvent

- contaminated reusable wipes from the definition of sol id waste ].

g Equation used to calculate the present value of benefits is discussed in Section 4.1 of this document.

h Equation used in annualizing benefits is discussed in Section 4.1 of this document.



## 5.2. Expected Pollution Prevention and Waste Minimization Benefits

For purposes of this analysis, the pollution prevention and waste minimization benefits of the

final rule would take the form of avoiding future purchases of virgin solvents if captured spent

solven t “free liquids” are recycled. In estimating these benefits

, the analysis relies on monetized benefit estimates (calculated in dollars per ton of spent solvent “free liquids” captured) used in the economic background document originally developed for the proposed rule. 126

, 127



## Generators o f solvent

- contaminated wipes have the potential to capture and recycle spent solvent “free liquids.” Under the final rule, solvent

- contaminated reusable wipes must contain

“ no free liquids” at the point of being laundered or dry

- cleaned on

- site or at the point of being transported off

- site for laundering or dry

- cleaning . Similarly, solvent

- contaminated disposable wipes must contain “no free liquids” w hen transported to a landfill or combustor

. Therefore, generators of solvent

- contamina ted reusable and disposable wipes must remove (i.e., decant) containers in order for their wipes to be eligible for the conditional exclusions under the final rule. However, the final rule will lead to incremental pollution prevention and waste minimizati on

126 

### U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation

. July 17, 2 003. pp. 23

- 24.

127 

### In addition to the benefit of avoiding future purchases of virgin solvents if captured spent solvent “free liquids” are recycled, the potential environmental benefit of capturing (removing) spent solvent “free liquids” and preventing them from loading ei ther into the air, land, or surface waters (via evaporation/volatilization, spills/leakages, or laundry effluent wastewaters) is not monetized in this analysis.

### 75 

## benefits only for solvent

- contaminated disposable wipes, not solvent

- contaminated reusable wipes. 128



## Furthermore, under the hazardous waste regulations, large quantity generators (LQGs) have only 90 days to accumulate solvent

- contaminated wipes. Howev er, under the final rule, generators may accumulate solvent

- contaminated wipes, along with free liquids, for up to 180 days. Longer accumulation periods increase the potential for a generator to accumulate sufficient amounts of spent solvent to make recycl ing economically feasible.

Exhibit 5

- 2 shows the estimated quantity of spent s olvent “free liquids” removed from containers

filled with solvent

- contaminated disposable wipes in the s tates that are expected to adopt the final rule. The estimated quantity of spent solvent “free liquids” shown in Exhibit 5

- 2 was derived in Chapter 4 (Section 4. 3 .7). To estimate pollution prevention and waste minimization

benefits , the quantity of spent solvent “free liquids” is multiplied by monetized benefit estimates

rang ing from $810 to $3,664 per ton (2011 dollars). These monetized benefit estimates are based on volatile organic compound (VOC) emissions reduction health benefits that EPA applied in three earlier rulemakings promulgated in 1997, 1998, and 2000. 129

, 130 

## The per

- ton benefit estimates in the economic background document for the proposed rule have been updated to 2011 dollars using GDP deflators developed by the U.S. Department of

Commerce. 131

128 

### The analysis assumes that, under existing state policies, solvent

- contaminated reusable wip es already must contain “no free liquids” and, consequently, generators of solvent

- contaminated reusable wipes are currently capturing and recycling spent solvent “free liquids.” Therefore, for solvent

- contaminated reusable wipes, there are no

incremental pollution prevention and waste minimization benefits associated with the final rule.

129 

### For additional information on these three rulemakings, refer to the following data sources: (1) EPA’s Office of Air and Radiation, Regulatory Impact Analyses for the Particulate Matter and Ozone National Ambient Air Quality Standards and Proposed Regional Haze Rule , July 17, 1997, http://www.epa.gov/ttn/oarpg/naaqsfin/ria.html ; (2) EPA’s Office of Water, Eco nomic Analysis of Final Effluent Limitations Guidelines and Standards for the Pharmaceutical Manufacturing Industry , July 30,1998, http://www.epa.gov/ost/guide/pharm/econanal/econanal.p df ; and (3) EPA’s Office of Water, “Effluent Guidelines for the Oil and Gas Extraction Point Source Category: Proposed
Rule,” 65 FR 21567, April 21, 2000, http://www.epa.gov/waterscience/ guide/sbf/sbfnoda.pdf

.

130 

### Many VOCs are carcinogens or contribute to the formation of particulate matter and ozone (i.e., air pollution). In the three rulemakings referenced above, VOC emissions reduction health benefits include reduction in mortality; cancer risk; chronic and a cute bronchitis; hospital admissions due to respiratory problems, congestive heart failure, and ischemic heart disease; lower and upper respiratory symptoms; and work loss days.

131 

### U.S. Department of Commerce, Bureau of Economic Analysis

. “ Table 1.1.9. Implicit Price Deflators for

Gross Domestic Product

. ” Available online at: http://www.bea.gov/national/nipaweb/TableView.asp?SelectedTa ble=13&Freq=Qtr&FirstYear=2006&LastYear=2008

, last accessed on November 6 , 2011. Year 1998, Quarter IV = 85.988 and Year 2011 , Quarter III = 113.823

.

### 76 

## Exhibit 5

- 2

Annual Pollution Prevention and

Waste Minimization Benefits of the Final Rule , 2011 Dollars

Type of Wipe s Annual Tons of

Solvent Removed

from Containers Annual Pollution Prevention

and Waste Minimization Benefits

Lower Bound b Upper Bound c

Reusable Wipes Not Applicable Not Applicable Not Applicable

Disposable Wipes 262 a $0.21 million $0.96 million

Total 262 $0. 21 million $0. 96 million

a The estimated quantity of solvent captured by decanting on

- site accumulation containers was taken from Chapter 4 (Section 4. 3 .7) and converted to tons using a conversion factor of 0.0039 tons/gallon.

b Lower Bound = [Annual Tons of Solvent Captured] x [ $810/ton].

c Upper Bound = [Annual Tons of Solvent Captured] x [ $3,664/ton].



## As shown in Exhibit 5

- 2, under the final rule, t he total annual benefit associated with avoiding future purchases of virgin solvents is estimated to be between $0. 21 million and $0. 96 million.



## 5.3

. Expected Fire Safety Benefits

EPA anticipates that the final rule will result in wipe

- related fire safety benefits as a result of several specific rule conditions :

• Wipes must be stored in non

‐ leaking , closed containers. This condition ensures that the wipes are contained and are not exposed to the environment (and potential ignition sources).

• Wipes must be labeled "E xcl uded Solvent

‐ Contaminated Wipes." This condition ensures that the generator s and handler s are aware of the contents of the containers and can handle them appropriately (e.g., not store the wipes next to an open flame). Although 46 states have similar req uirements as the final rule, they do not have the labeling requirement.

• Wipes must contain "no free liquids

. " Because of this condition , the likelihood of starting

a fire from solvent

- contaminated wipes is greatly reduced.

The above conditions are expected to minimize fugitive air emissions, secure the solvent

contaminated wipes from potentially incompatible wastes or ignition sources, and prevent spills of “free liquids,” resulting in a reduction in the risk of fires.

G ene rators and handlers in states that have exemptions/exclusions for solvent

- contaminated

reusable wipes are not currently subject to the hazardous waste regulations; only generators

and handlers of solvent

- contaminated disposable wipes are subject to the haz ardous waste regulations. In addition, EPA has determined that the conditions of the final rule maintain the

same level of fire protection as the existing hazardous waste regulations for disposable wipes

. Therefore, EPA expects there would be no incremen tal fire safety benefits associated with

### 77 

## solvent

- contaminated disposable wipes from this rule . In contrast, EPA expects there would be fire safety benefits associated with solvent

- contaminated reusable wipes from this rule

.

For purposes of this analysis, fire safety benefits of the final rule are estimated as a percentage of the costs associated with structure fires caused by spontaneous combus tion 132 

## or chemical

reaction of oily rags

. The cost of structure fires caused by spontaneous combustion or chemica l reaction of oily rags is estimated at $11.18 million per year (2011 dollars). This estimate is based on average property damage cost data developed by the National Fire Protection

Association for the 2005

- 2009 period. 133



## To estimate the maximum achieva ble fire safety benefit, the cost of structure fires caused by
spontaneous combustion or chemical reaction of oily rags is assigned in proportion to the percent of facilities that generate solvent

- contaminated reusable wipes and are located in the states that are expected to choose to adopt the final rule. That is, the cost of structure fires caused by spontaneous combustion or chemical reaction of oily rags is multiplied by the percent of facilities that generate solv ent

- contaminated reusable wipes and are located in the states that are expected to adopt the final rule. The calculation to estimate the maximum achievable fire safety benefit is illustrated below:

Maximum

Achievable Fire Safety

Benefit = [Cost of Struct ure Fires Caused by Spontaneous

Combustion or Chemical

Reaction of Oily Rags ($/year)] X [ Total Number of Generators (LQGs and SQGs)

of Solvent

- Contaminated Reusable Wipes in states that Are Expected to Adopt the Final Rule ]

[ Total Number of Facilities in Economic Sub

- Sectors with

Generators of Solvent

- Contaminated Wipes (All States) ]



## B ased on the above equation, the maximum achievable fire safety benefit associated with the final rule is estimated to be $ 2.31 million per year (i.e., $11.18 million per year x [62,478 LQGs and SQGs that use primarily reusable wipes (Exhibit 3

- 1) / 302,483 facilities that generate

solvent

- contaminated wipes ( Exhibit 2

- 3)]).

For this analysis, EPA estimates a range of fire safety benefits because EPA cannot pr ecisely estimate the actual dollar benefit due to the final rule. While there is a good source of information on the damage costs of structure fires caused by spontaneous combustion or

132 

### Spontaneous combustion is a byproduct of spontaneous heating, which occurs when a material

increases in temperature without drawing heat from its surroundings. If the material reaches its ignition temperature, spontaneous ignition or combustion occurs. National Fire Protection Association. Fires Caused by Spontaneous

Combustion or Chemical Reaction . N ovember 2011. p. 2. Available online at: http://www.nfpa.org/assets/files/pdf/combustionexecsum.pdf , last accessed on June 5, 2012.

133 

### National Fire Protection Association. Fires Caused by Spontaneous Combustion or Chemical Reaction

. November 2011. pp. 30, 34, 44, and 53. Available online at: http://www.nfpa.org/assets/files/pdf/combustionexecsum.pdf , last accessed on June 5, 2012. For purposes of this analysis, it was assumed that the 2005

- 2009 average property damage cost of $10.8 million per year was stated in 2009 dollars. This analysis updated it to 2011 dollars using GDP deflators developed by the U .S. Department of

Commerce. The estimated cost in 2011 dollars might be understated because the data source used in this analysis

did not indicate whether t he property damage cost data were reported in 2009 dollars or prior year dollars. U.S. Department of Commerce, Bureau of Economic Analysis. “Table 1.1.9. Implicit Price Deflators for Gross Domestic

Product.” Available online at:

ht tp://www.bea.gov/national/nipaweb/TableView.asp?SelectedTable=13&Freq=Qtr&FirstYear=2006&LastYear=2008

, last accessed on November 6, 2011. Year 2009, Quarter IV = 109.943 and Year 2011, Quarter III = 113.823.

### 78 

## chemical reaction of oily rags, there is greater uncertainty about the extent to which this rule will reduce fires. Therefore, we have assumed that the minimum fire safety benefit associated with the final rule would be 10 percent of the maximum achievable fire safety benefit.

Exhibit 5

- 3 summarizes the annual potential fi re benefits of the final rule.

Exhibit 5

- 3 Annual Fire Safety Benefits of the Final Rule , 2011 Dollars

Type of Wipe s Annual Fire Safety Benefits

Lower Bound a Upper Bound b

Reusable Wipes $0.23 million $2.31 million

Disposable Wipes Not Applicable Not Applicable

Total $0.23 million $2.31 million

a Lower Bound = [10 percent of Upper Bound].

b Upper Bound = [$11.18 million/year] x [62,478 LQGs and SQGs that use primarily reusable wipes] / [302,483 facilities that generate solvent

- contaminated wipes].



## As shown in Exhibit 5

- 3, under the final rule, t he total annual benefit associated with avoiding

structure fires caused by spont aneous combustion or chemical reaction of solvent

- contaminated wipes is estimated to fall between $0.23 million and $2.31 million

.



## 5.4. Expected Benefits to Industrial Laundries from Excluding Solvent

Contaminated Reusable W ipes from the D efinition of S olid W aste

In a May 23, 2001 meeting between EPA and reusable wipes suppliers, at least one supplier indicated that reusable wipes suppliers (i.e., industrial laundries) want to avoid the negative

market impact on a product of being labeled as a form of “waste.” Although 45 states provide regulatory relief for reusable solvent

- contaminated wipes, as long as certain basic conditions are met, not all of them exclude reusable solvent

- contaminated wipes from the definition of so lid

waste. Under the final rule, solvent

- contaminated reusable wipes will be excluded from solid
waste classification. As a result, solvent

- contaminated reusable wipes could realize cachet 134



## value from not being labeled as a form of “waste”

.

The potentia l magnitude of this benefit has been estimated as follows, drawing on assumptions used in the economic background document originally developed for the proposed rule. 135



## These assumptions include:

134 

### “Cachet” is defined as a seal or mark used especially to designate official approval; an indication of approval carrying great prestige; a characteristic feature or quality conferring prestige. Labeling a product as a form of waste may reduce the econom ic value of a product to levels below what one would expect when one takes into account the health/safety risk associated with it. There also are mechanisms that may contribute to the social amplification of stigma such as mass media reports, litigation, and increased regulation of an industry (Flynn, et al., 2001, p. 355).

135 

### U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardou s Waste Regulation

. July 17, 2003. p. 172.

### 79 

## • 50 percent of the s tates currently exclude solvent

- contamin ated reusable wipes from solid waste regulatory classification

. 136



## • The remaining 50 percent of the s tates currently exclude solvent

- contaminated reusable wipes from hazardous waste regulatory classification, but not from solid waste

classification. 137



## • On average, industrial laundry revenue per (laundered) wipe is $0.066 (2011 dollars). The per

- wipe revenue estimate in the economic background document for the proposed rule has been updated to 2011 dollars using GDP deflators developed by the U.S. Depart ment of Commerce. 138



## • Based on empirical findings from a study that measured changes in property values due
to environmental contamination, EPA estimated that

, labeling a product as “waste” may
result in a 10 percent average loss in product value. 139 

## Since there is uncertainty associated with estimating the loss in product value associated with the labeling of

solvent

- contaminated reusable wipes as a form of waste , EPA has assumed a range of product value loss from 5% to 10%

.

Based on the above assumptions , of the 2.0 billion solvent

- contaminated reusable wipes generated each year (Exhibit 2

- 7), 50 percent or 1.0 billion solvent

- contaminated reusable wipes are generated in s tates that currently exclude solvent

- contaminated reusable wipes from

hazardous waste regulatory classification only.

136 

### This assumption was obtained from the economic background document developed for the proposed rule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background

Documen t

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 172.

137 

### This assumption was obtained from the economic background document developed for the proposed

r ule, and is based on judgment by ORCR staff. U.S. Environmental Protection Agency. Economics Background

Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 172.

EPA only estimated benefits for facilities located in states that currently exclude reusable wipes from hazardous waste, but not solid waste regulation. Facilities in states that already exclude reusable wipes from solid

waste classification were not included in this estimate.

138 

### U.S. Department of Commerce, Bureau of Economic Analysis

. “ Table 1.1.9. Implicit Price Deflators for

Gross Domestic Product

. ” Available online at: http://www.bea.gov/national/nipaweb/TableView.asp?SelectedTable=13&Freq=Qtr&FirstYear=2006&LastYear=2008

, last accessed on November 6 , 2011. Year 2003, Quarter II = 93.815 and Year 2011 , Quarter III = 113.823

.

139 

### EPA does not have specific data regarding to what extent the negative impression that may be caused by solid waste classification impacts on the reusable wipe s market. However, EPA used empirical findings from a study that measured changes in property values in James Flynn, Paul Slovic, and Howard Kunreuther. Risk, Media, and Stigma: Understanding Public Challenges to Modern Science and Technology

. Earthscan P ublications Ltd.,

London. 2001

. to estimate the benefits of avoided waste “ stigma ” to be 10% of product value. Since there is uncertainty associated with estimating the loss in product value associated with the “waste” label , EPA has assumed a range of product value loss from 5% to 10%. Economic loss from the “stigma” associated with hazardous chemical/material contamination is basically defined and measured as the difference in the market value of non

contaminated product or property, compared to the market value of comparable but contaminated product or property which has been fully remediated (i.e., cleaned

- up or decontaminated). “Stigma” encompasses an intangible concept of perceived risk that lies beyond remediation costs and includes further discounts to compensate investors, purchasers, and/or lenders with the perceived risks a ssociated with formerly contaminated products or property. The inference is that stigma may continue to affect product or property values without real or observable contamination (ibid, p.189).

### 80 

## To estimate annual industrial laundry revenues, the affected number of solvent

- contaminated

reusable wipes is multiplied by the industrial laundry revenue per wipe. This calculation results

in estimated annual indu strial laundry revenues of $ 65.9 million (i.e., 1.0 billion wipes x $0.066/wipe). Therefore, the potential benefit to industrial laundries by excluding solvent

contaminated reusable wipes from the definition of solid waste ranges from $ 3.3 million per yea r ( i.e. , 5 percent of $ 65.9 million/year) to $ 6.6 million per year ( i.e. , 10 percent of $ 65.9 million/year).

Exhibit 5

- 4 summarizes the benefits of excluding solvent

- contaminated reusable wipes from the

definition of solid waste for LQGs and SQGs

.

Exhibit 5

- 4

Annual Cachet Benefit to Industrial Laundries from Excluding Solvent

- Contaminated Reusable Wipes F rom the D efinition of S olid W aste

, 2011 Dollars

Type of Wipe s Annual Loss in Product Value (Sales Revenues)

Lower Bound a Upper Bound b

Reusable Wipes $3.3 million $6.6 million

Disposable Wipes Not Applicable Not Applicable

Total $ 3.3 million $ 6.6 million

a Lower Bound = [5 percent of Annual Loss in Product Value], where [Annual Loss in Product Value] = [50 percent

of 2.0 billion solvent

- contaminated reusable wipes].x [ $0.066/wipe ].

b Upper Bound = [10 percent of Annual Loss in Product Value] ], where [Annual Loss in Pro duct Value] = [50 percent of 2.0 billion solvent

- contaminated reusable wipes].x [ $0.066/wipe ].

### 81 

# 6. Comparison of Benefits to Costs

This chapter compares benefits to costs in order to estimate the net benefits of the final rule. The chapter also presents the results of a sensitivity analysis conducted to determine whether, and to what extent, the results of the anal ysis are sensitive to changes in key assumptions and numeric inputs.



## 6.1. Net Benefits of the Final Rule

This section compares benefits to costs in order to estimate the net benefits of the final rule. Based on this comparison, the final rule will result in net savings.

Exhibit 6

- 1 presents the costs and benefits of the final rule. As shown in the exhibit, the annual

net benefits of the final rule are estimated at between $ 21.7 million and $ 27.8 million (2011 dollars) , regardless of discount rate . Therefore, EPA can certify that the final rule is not a n

“ economic ally signi ficant regulatory action” under S ection 3(f)(1) of Executive Order 1286 6 ( Regulatory Planning and Review ). 140

140 

### Under Section 3(f)(1) of Executive Order 12866, Regulato ry Planning and Review, a "significant regulatory action" means any regulatory action that is likely to result in a rule that may have an annual effect on the economy of $100 million or more or adversely affect in a material way the economy, a sector of th e economy, productivity, competition, jobs, the environment, public health or safety, or state, local, or tribal governments or

communities.

### 82 

## Exhibit 6

- 1 Comparison of Benefits to Costs under the Final Rule , 2011 Dollars a

Type of Impact s 7% 3% 0%

Discount Rate Discount Rate Discount Rate

Benefits

Annual Regulatory Compliance Savings (i.e., avoided costs) b $24,375,585 $24,375,585 $24,375,585

Other Annual Expected Benefits c $3,736,647 to $9,856,5 4 6 $3,736,647 to $9,856, 5 46 $3,736,647 to $9,856, 546

Total Benefits $28,112,232 to $ 34

, 232

, 131 $ 28,112,232 to $ 34

, 232

, 131 $ 28,112,232 to $ 34

, 232

, 131

Costs

Annual Regulatory Compliance Costs d, e $6,424,899 $6,401,231 $6,384,241

Total Costs $6,424,899 $6,401,231 $6,384,241

Net Benefits

Net Benefits f $21,687,333 to $ 27,807, 231 $21,711,001 to $ 27

, 830

, 900 $ 21

, 727,991 to $ 27

, 847

, 890

a Costs and benefits are evaluated over a 10

- year period.

b Annual regulatory c ompliance savings are reported as estimated in Exhibit 4

- 1 of this document , and include: (1) management of “free liquids” removed from containers, (2) avoided hazardous waste manifest costs, (3) avoided disposal costs, (4) avoided RCRA information collection r equirement costs to SQGs that may become CESQGs, and (5) avoided s tate waste fees and taxes.

c Other annual expected benefits are reported as estimated in Exhibit 5

- 1 of this document , and include: (1) pollution prevention and waste minimization benefits, (2) fire safety benefits, and (3) benefits to industrial laundries by excluding sol vent

- contaminated reusable wipes from the definition of solid waste

.

d Annual regulatory c ompliance costs are reported as estimated in Exhibit 4

- 1 of this document , and include: (1) reading the final rule, (2) management of “free liqu ids” removed from containers, (3 ) avoided ha zardous waste manifest costs, (4) avoided disposal costs, (5 ) avoided RCRA information collection requirement costs to SQG s that may become CESQGs, and (6 ) avoided s tate waste fees and taxes

.

e Annual regulatory compliance costs include annualized one

- time costs as well as annual costs.

f Net Benefits = [Total Benefits]

- [Total Costs].



## 6.2. Sensitivity Analys i s

This section presents a sensitivity analysis in order to determine whether, and to what extent, the results of the analysis are sensitive to changes in key assumptions and numeric inputs. The sensitivity analysis estimates economic impacts according to the three alternative sets of
parameter s shown in Exhibit 6

- 2 :

• Lowe r Bound Values. Lowest estimate of number of entities directly impacted, as well as minimum unit values and quantities.

• Most Likely Values. EPA’s “best judgment” for key parameters (which do not necessarily
represent the mid

- point between the lower and upper bound). These values reflect the key assumptions and numeric inputs discussed in Chapters 2 through 5 of this

document.

• Upper Bound Values. Highest estimate of number of entities impacted, as well as maximum unit values and quantities.

### 83 

## Exhibit 6

- 2 presents the assumptions associated with key parameters used in the sensitivity analysis. These assumptions are shown in percentages. These percentages are applied to the number of generators and handlers of solvent

- contaminated wipes and to the numbe r of

solvent

- contaminated wipes, as appropriate, in order to analyze the sensitivity of the costs and

benefits of the final rule . The percentages presented in Exhibit 6

- 2 are taken directly from the economic background document originally developed for t he proposed rule. 141



## Exhibit 6

- 2 Assumptions Associated with Key Parameters Used

in Sensitivity Analysis of Economic Impact Estimation

Cost Element s Lower

Bound Most Likely Upper

Bound

Affected

Universe Percent of s tates that are expected to adopt the final rule 50% 75% 100%

Containers

for Solvent

Contaminated Wipes Percent of wipes not currently accumulated, stored, and transported in closed containers 25% 50% 80%

Management of "Free Liquids" Percent of solvent

- contaminated wipes

with "free liquids" Printers 90% 100% 100%

Non

- Printers 40 % 50 % 60%



## In conducting the sensitivity analysis, EPA re

- computed the annual costs and benefits of the

final rule using the lower

- bound and the upper

- bound parameters shown in Exhibit 6

- 2. The results of the sensitivity analysis are presented in Exhibit 6

- 3.

Exhibit 6

- 3

Net Annual Benefits of the Final Rule Based on the Sensitivity Analysis, 2011 Dollars a , b

Alternative

Set of Parameters 7%

Discount Rate 3%

Discount Rate 0%

Discount Rate

Lower Bound $ 15, 590,382 to $ 20, 705,549 $ 15, 614,050 to $ 20, 729,217 $ 15, 631,040 to $ 20, 746,207

Most Likely $21,687,333 to $27,807, 2 31 $21,711,001 to $27,830, 9 00 $21,727,991 to $27,847, 890

Upper Bound $ 27,6 22

, 585 to $ 34, 735,348 $ 27, 646,254 to $ 34, 759,016 $ 27, 663,243 to $ 34, 776,006

a E xcept for the us e of the percentages shown in Exhibit 6

- 2, the methodology used to estimate the annualized costs

and benefits of the final rule for the lower

- bound and the upper

- bound alternatives is the same as presented in Chapters 4 (for costs) and 5 (for benefits).

b Costs and benefits are evaluated over a 10

- year period.

141 

### U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation

. July 17, 2003. pp. 31

- 35.

### 84 

## As shown in the exhibit, the net annual benefits of the final rule are estimated to be between $1 5.6 million and $ 34.8 million (2011 dollars), depending on the alternative set of parameters

used to estimate the costs and benefits. In all cases

, EPA concludes that the final rule is not a n

“ economically signi ficant regulatory action” under S ection 3(f)(1) of Executive Order 12866

.

### 85 

# 7. Supplemental Analyses Required by Congressional Statutes or

White House Executive Orders

This chapter p resent s supp lemental analyses for Congressional statutes and White House

Executive Orders.



## 7.1. Regula tory Flexibility Act (RFA), as A mended by the Small Business Regulatory Enforcement Fairness Act (SBREFA)

The Regulatory Flexibility Act (RFA), as amended by the Small Business Regulatory Enforcement Fairness Act (SBREFA), requires EPA to prepare a regulatory flexibility analysis and convene a Small Business Advocacy Review (SBAR) Panel of any rule subject to notice and comment rulemaking requirements under the Administrative Procedure Act (APA) or any other statute, unless the A gency can certif y that the rule will not have a significant economic impact on a substantial number of small entities. Small entities include small businesses, small organizations, and small governmental jurisdictions.

This analysis document s the Agency’s basis for certi fying that the final rule will not result in a significant economic impact on a substantial number of small entities. 142 

## In making this determination, the analysis first identifies the industries ( based on five

- or six

- digit NAICS code )

that will be affecte d by the final rule. For each of the industries, the analysis estimates the

number of small affected entities . The analysis then compares the average compliance cost per
entit y, regardless of size, with the estimated revenue for the smallest of the small entities, firms with one employee . The ratio of compliance cost as a percentage of revenue is one of the impact measures recommended in EPA guidance for assessing a rule's economic impact on

small e ntities

. 143 

## The analysis assumes that small entities incurring incremental costs of less than one percent will not face significant economic impacts as a result of the final rule.

The final rule will affect various entities that generate or handle solvent

- contami nated reusable or disposable wipes (LQGs, SQGs, and handling facilities). These entities are characterized in Chapter 2 of this document. However, all affected entities generating or handling solvent

contaminated disposable wipes are expected to incur sa vings as a result of the final rule (see

Exhibit 4

- 3 of this document). Consequently, these small entities are not expected to incur any adverse impact as a result of the final rule.

142 

### Generally, the certification is based on an analysis that considers the small affected entities and

compares their compliance cost s to t he ir revenue s . However, a conservative approach was taken to analyze the economic impacts on these small affected entities. An analysis of average compliance cost per entity, regardless of

size (including larger entities) , and revenue generated by the sm allest of small entities, firms with only one employee was conducted to certify that the final rule will not result in significant economic impact s on a substantial number of small entities. Using average cost per entity, regardless of size, will overesti mate the economic impact s on small entities because smaller operations use fewer rags and wipes compared to larger operations and therefore, have lower compliance costs. Similarly, using revenue estimates based on firms with only one employee will

underes timate the revenue generated by small entities because many, if not most affected small entities will have more than one employee and

, thus, will generate higher levels of revenue to support more employees. Because the resulting impacts are less than one percent (i.e., cost as a percent of revenue) , EPA conclude d that the majority of small entities will not face significant economic impacts as a result of the final rule.

143 

### U.S. Environmental Protection Agency. Final Guidance for EPA Rulewriters: Regulatory Flexibility Act as Amended by the Small Business and Regulatory Enforcement Fairness Act . November 2006. Available at: http://www.epa.gov/rfa/documents/Guidance

- RegFlexAct .pdf , last accessed on December 19, 2011.

### 86 

## The analysis and results are summarized in Exhibit 7

- 1 and are descri bed in more detail in the following paragraphs.

### March 16, 2012 DRAFT 87 

## Exhibit 7

- 1 Small Business Size Standards, Number of Affected Small Entities, Per

- Facility Costs, Estimated Revenue, and Economic Impact Measure for Industries Affected by the Final Rule a , b



### Economic Sub

- Sectors with Generators of Solvent

- Contaminated Wipes

Economic

Sub

- Sector s Industries (5

- or 6

- Digit NAICS Code) c, d SBA Size

Standard

for Small

Businesses e Estimated

Revenue for Entity

with One Employee

(2011 Dollars) f LQGs that Use Primarily Reusable Wipes SQGs that Use Primarily Reusable Wipes LQGs that Use Primarily Disposable Wipes SQGs that Use Primarily Disposable Wipes All Generators

Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) i Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) i Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) i Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) h Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities

Over 1% Percent

of

Affected

Small

Enti ties

Over 1%

Printing 323110 < 500 Employees $235,891 10 $495 0.21% 5,306 $98 0.04% 1 ($11,851)

- 461 ($1,218)

- 0 0.00%

323111 < 500 Employees $165,574 8 $495 0.30% 117 $98 0.06% 1 ($11,851)

- 10 ($1,218)

- 0 0.00%

323112 < 500 Employees $397,617 4 $495 0.12% 357 $98 0.02% 0 ($11,851)

- 31 ($1,218)

- 0 0.00%

323113 < 500 Employees $174,561 1 $495 0.28% 2,157 $98 0.06% 0 ($11,851)

- 188 ($1,218)

- 0 0.00%

323114 < 500 Employees $105,164 0 $495 0.47% 3,143 $98 0.09% 0 ($11,851)

- 273 ($1,218)

- 0 0.00%

323115 < 500 Employees $148,186 0 $495 0.33% 815 $98 0.07% 0 ($11,851)

- 71 ($1,218)

- 0 0.00%

323116 < 500 Employees $612,537 0 $495 0.08% 213 $98 0.02% 0 ($11,851)

- 19 ($1,218)

- 0 0.00%

323117 < 500 Employees $284,476 0 $495 0.17% 221 $98 0.03% 0 ($11,851)

- 19 ($1,218)

- 0 0.00%

323118 < 500 Employees $173,974 0 $495 0.28% 85 $98 0.06% 0 ($11,851)

- 7 ($1,218)

- 0 0.00%

323119 < 500 Employees $105,239 1 $495 0.47% 1,025 $98 0.09% 0 ($11,851)

- 89 ($1,218)

- 0 0.00%

323121 < 500 Employees $165,487 0 $495 0.30% 467 $98 0.06% 0 ($11,851)

- 41 ($1,218)

- 0 0.00%

323122 < 500 Employees $92,254 2 $495 0.54% 643 $98 0.11% 0 ($11,851)

- 56 ($1,218)

- 0 0.00%

Publishing (printed matter) 51111 < 500 Employees $109,363 0 $461 0.42% 2,499 $94 0.09% 0 ($10,653)

- 217 ($1,089)

- 0 0.00%

51112 < 500 Employees $377,341 0 $461 0.12% 2,770 $94 0.02% 0 ($10,653)

- 241 ($1,089)

- 0 0.00%

51113 < 500 Employees $156,368 0 $461 0.29% 1,371 $94 0.06% 0 ($10,653)

- 119 ($1,089)

- 0 0.00%

51114 < 500 Employees $235,415 0 $461 0.20% 491 $94 0.04% 0 ($10,653)

- 43 ($1,089)

- 0 0.00%

51119 < 500 Employees $316,855 1 $461 0.15% 553 $94 0.03% 0 ($10,653)

- 48 ($1,089)

- 0 0.00%

Business

Services (copy shops) 561439 < $7 Million

Annual Revenue $145,696 1 $450 0.31% 1,145 $93 0.06% 0 ($10,281)

- 100 ($1,040)

- 0 0.00%

## Exhibit 7

- 1 (continued) Small Business Size Standards, Number of Affected Small Entities, Per

- Facility Costs, Estimated Revenue, and Economic Impact Measure for Industries Affected by the Final Rule a



### 88 Economic Sub

- Sectors with Generators of Solvent

- Contaminated Wipes

Economic

Sub

- Sector s Industries (5

- or 6

- Digit NAICS Code) c, d SBA Size

Standard

for Small

Businesses e Estimated

Revenue for Entity

with One Employee

(2011 Dollars) f LQGs that Use Primarily Reusable Wipes SQGs that Use Primarily Reusable Wipes LQGs that Use Primarily Disposable Wipes SQGs that Use Primarily Disposable Wipes All Generators

Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) i Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) i Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) i Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) h Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities

Over 1% Percent

of

Affected

Small

Enti ties

Over 1%

Chemical

and Allied

Products 211112 < 500 Employees $1,761,649 0 $364 0.02% 14 $112 0.01% 0 ($27,151)

- 1 ($6,880)

- 0 0.00%

32511 < 1,000 Employees $294,240 1 $364 0.12% 3 $112 0.04% 0 ($27,151)

- 0 ($6,880)

- 0 0.00%

32512 < 1,000 Employees $639,081 0 $364 0.06% 10 $112 0.02% 0 ($27,151)

- 1 ($6,880)

- 0 0.00%

325131 < 1,000 Employees $330,780 1 $364 0.11% 7 $112 0.03% 0 ($27,151)

- 1 ($6,880)

- 0 0.00%

325132 < 750 Employees $343,876 1 $364 0.11% 10 $112 0.03% 0 ($27,151)

- 1 ($6,880)

- 0 0.00%

325181 < 1,000 Employees $460,389 0 $364 0.08% 3 $112 0.02% 0 ($27,151)

- 0 ($6,880)

- 0 0.00%

325182 < 500 Employees

- 0 $364

- 1 $112

- 0 ($27,151)

- 0 ($6,880)

- - -

325188 < 1,000 Employees $858,195 4 $364 0.04% 39 $112 0.01% 0 ($27,151)

- 3 ($6,880)

- 0 0.00%

325191 < 500 Employees $355,140 0 $364 0.10% 5 $112 0.03% 0 ($27,151)

- 0 ($6,880)

- 0 0.00%

325192 < 750 Employees $613,182 0 $364 0.06% 2 $112 0.02% 0 ($27,151)

- 0 ($6,880)

- 0 0.00%

325193 < 1,000 Employees $5,561,097 0 $364 0.01% 30 $112 0.00% 0 ($27,151)

- 3 ($6,880)

- 0 0.00%

325199 < 1,000 Employees $1,360,726 7 $364 0.03% 54 $112 0.01% 1 ($27,151)

- 5 ($6,880)

- 0 0.00%

325998 < 500 Employees $810,885 9 $364 0.04% 132 $112 0.01% 1 ($27,151)

- 11 ($6,880)

- 0 0.00%

331311 < 1,000 Employees $212,667 0 $364 0.17% 1 $112 0.05% 0 ($27,151)

- 0 ($6,880)

- 0 0.00%

## Exhibit 7

- 1 (continued) Small Business Size Standards, Number of Affected Small Entities, Per

- Facility Costs, Estimated Revenue, and Economic Impact Measure for Industries Affected by the Final Rule a



### 89 Economic Sub

- Sectors with Generators of Solvent

- Contaminated Wipes

Economic

Sub

- Sector s Industries (5

- or 6

- Digit NAICS Code) c, d SBA Size

Standard

for Small

Businesses e Estimated

Revenue for Entity

with One Employee

(2011 Dollars) f LQGs that Use Primarily Reusable Wipes SQGs that Use Primarily Reusable Wipes LQGs that Use Primarily Disposable Wipes SQGs that Use Primarily Disposable Wipes All Generators

Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) i Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) i Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) i Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) h Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities

Over 1% Percent

of

Affected

Small

Enti ties

Over 1%

Plastics

and Rubber 31332 < 1,000 Employees $242,185 7 $367 0.15% 17 $112 0.05% 1 ($27,607)

- 2 ($7,010)

- 0 0.00%

315299 < 500 Employees $166,288 0 $367 0.22% 51 $112 0.07% 0 ($27,607)

- 4 ($7,010)

- 0 0.00%

315999 < 500 Employees $218,587 0 $367 0.17% 82 $112 0.05% 0 ($27,607)

- 7 ($7,010)

- 0 0.00%

325991 < 500 Employees $470,938 3 $367 0.08% 59 $112 0.02% 0 ($27,607)

- 5 ($7,010)

- 0 0.00%

326113 < 500 Employees $478,738 7 $367 0.08% 64 $112 0.02% 1 ($27,607)

- 6 ($7,010)

- 0 0.00%

326121 < 500 Employees $425,156 1 $367 0.09% 61 $112 0.03% 0 ($27,607)

- 5 ($7,010)

- 0 0.00%

32613 < 500 Employees $308,226 7 $367 0.12% 28 $112 0.04% 1 ($27,607)

- 2 ($7,010)

- 0 0.00%

32614 < 500 Employees $1,357,239 0 $367 0.03% 51 $112 0.01% 0 ($27,607)

- 4 ($7,010)

- 0 0.00%

32615 < 500 Employees $492,198 1 $367 0.07% 57 $112 0.02% 0 ($27,607)

- 5 ($7,010)

- 0 0.00%

32616 < 500 Employees $1,245,605 0 $367 0.03% 22 $112 0.01% 0 ($27,607)

- 2 ($7,010)

- 0 0.00%

326191 < 500 Employees $177,794 1 $367 0.21% 66 $112 0.06% 0 ($27,607)

- 6 ($7,010)

- 0 0.00%

326192 < 750 Employees $107,375 1 $367 0.34% 4 $112 0.10% 0 ($27,607)

- 0 ($7,010)

- 0 0.00%

326199 < 500 Employees $375,035 14 $367 0.10% 790 $112 0.03% 2 ($27,607)

- 69 ($7,010)

- 0 0.00%

326211 < 1,000 Employees $341,923 1 $367 0.11% 9 $112 0.03% 0 ($27,607)

- 1 ($7,010)

- 0 0.00%

32622 < 500 Employees $513,576 1 $367 0.07% 22 $112 0.02% 0 ($27,607)

- 2 ($7,010)

- 0 0.00%

326291 < 500 Employees $445,488 3 $367 0.08% 52 $112 0.03% 0 ($27,607)

- 5 ($7,010)

- 0 0.00%

326299 < 500 Employees $370,958 6 $367 0.10% 78 $112 0.03% 1 ($27,607)

- 7 ($7,010)

- 0 0.00%

337215 < 500 Employees $319,668 1 $367 0.11% 111 $112 0.04% 0 ($27,607)

- 10 ($7,010)

- 0 0.00%

339113 < 500 Employees $212,023 4 $367 0.17% 225 $112 0.05% 0 ($27,607)

- 20 ($7,010)

- 0 0.00%

339932 < 500 Employees $156,400 0 $367 0.23% 94 $112 0.07% 0 ($27,607)

- 8 ($7,010)

- 0 0.00%

339991 < 500 Employees $204,194 1 $367 0.18% 68 $112 0.05% 0 ($27,607)

- 6 ($7,010)

- 0 0.00%

## Exhibit 7

- 1 (continued) Small Business Size Standards, Number of Affected Small Entities, Per

- Facility Costs, Estimated Revenue, and Economic Impact Measure for Industries Affected by the Final Rule a



### 90 Economic Sub

- Sectors with Generators of Solvent

- Contaminated Wipes

Economic

Sub

- Sector s Industries (5

- or 6

- Digit NAICS Code) c, d SBA Size

Standard

for Small

Businesses e Estimated

Revenue for Entity

with One Employee

(2011 Dollars) f LQGs that Use Primarily Reusable Wipes SQGs that Use Primarily Reusable Wipes LQGs that Use Primarily Disposable Wipes SQGs that Use Primarily Disposable Wipes All Generators

Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) i Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) i Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) i Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) h Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities

Over 1% Percent

of

Affected

Small

Enti ties

Over 1%

Fabricated

Metal

Products 332812 < 500 Employees $730,880 32 $360 0.05% 299 $110 0.02% 3 ($26,568)

- 26 ($6,735)

- 0 0.00%

332813 < 500 Employees $232,299 18 $360 0.15% 348 $110 0.05% 2 ($26,568)

- 30 ($6,735)

- 0 0.00%

339911 < 500 Employees $299,142 0 $360 0.12% 242 $110 0.04% 0 ($26,568)

- 21 ($6,735)

- 0 0.00%

339912 < 500 Employees $133,170 0 $360 0.27% 19 $110 0.08% 0 ($26,568)

- 2 ($6,735)

- 0 0.00%

339914 < 500 Employees $77,565 0 $360 0.46% 79 $110 0.14% 0 ($26,568)

- 7 ($6,735)

- 0 0.00%

Industrial Machinery and

Equipment 314999 < 500 Employees $181,095 0 $415 0.23% 296 $124 0.07% 0 ($34,356)

- 26 ($8,676)

- 0 0.00%

332323 < 500 Employees $147,765 1 $415 0.28% 355 $124 0.08% 0 ($34,356)

- 31 ($8,676)

- 0 0.00%

33241 < 500 Employees $1,172,743 1 $415 0.04% 34 $124 0.01% 0 ($34,356)

- 3 ($8,676)

- 0 0.00%

332991 < 750 Employees $499,154 0 $415 0.08% 12 $124 0.02% 0 ($34,356)

- 1 ($8,676)

- 0 0.00%

333111 < 500 Employees $324,274 3 $415 0.13% 149 $124 0.04% 0 ($34,356)

- 13 ($8,676)

- 0 0.00%

33312 < 750 Employees $583,597 3 $415 0.07% 88 $124 0.02% 0 ($34,356)

- 8 ($8,676)

- 0 0.00%

33322 < 500 Employees $314,635 0 $415 0.13% 69 $124 0.04% 0 ($34,356)

- 6 ($8,676)

- 0 0.00%

333295 < 500 Employees $673,464 2 $415 0.06% 23 $124 0.02% 0 ($34,356)

- 2 ($8,676)

- 0 0.00%

333298 < 500 Employees $256,551 1 $415 0.16% 166 $124 0.05% 0 ($34,356)

- 14 ($8,676)

- 0 0.00%

333319 < 500 Employees $507,088 1 $415 0.08% 166 $124 0.02% 0 ($34,356)

- 14 ($8,676)

- 0 0.00%

333414 < 500 Employees $227,172 0 $415 0.18% 51 $124 0.05% 0 ($34,356)

- 4 ($8,676)

- 0 0.00%

333511 < 500 Employees $139,846 1 $415 0.30% 270 $124 0.09% 0 ($34,356)

- 23 ($8,676)

- 0 0.00%

333512 < 500 Employees $143,050 1 $415 0.29% 75 $124 0.09% 0 ($34,356)

- 7 ($8,676)

- 0 0.00%

333513 < 500 Employees $197,809 0 $415 0.21% 38 $124 0.06% 0 ($34,356)

- 3 ($8,676)

- 0 0.00%

333514 < 500 Employees $104,804 0 $415 0.40% 428 $124 0.12% 0 ($34,356)

- 37 ($8,676)

- 0 0.00%

333515 < 500 Employees $326,685 0 $415 0.13% 202 $124 0.04% 0 ($34,356)

- 18 ($8,676)

- 0 0.00%

## Exhibit 7

- 1 (continued) Small Business Size Standards, Number of Affected Small Entities, Per

- Facility Costs, Estimated Revenue, and Economic Impact Measure for Industries Affected by the Final Rule a



### 91 Economic Sub

- Sectors with Generators of Solvent

- Contaminated Wipes

Economic

Sub

- Sector s Industries (5

- or 6

- Digit NAICS Code) c, d SBA Size

Standard

for Small

Businesses e Estimated

Revenue for Entity

with One Employee

(2011 Dollars) f LQGs that Use Primarily Reusable Wipes SQGs that Use Primarily Reusable Wipes LQGs that Use Primarily Disposable Wipes SQGs that Use Primarily Disposable Wipes All Generators

Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) i Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) i Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) i Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) h Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities

Over 1% Percent

of

Affected

Small

Enti ties

Over 1%

Industrial Machinery and

Equipment (continued) 333518 < 500 Employees $419,408 0 $415 0.10% 48 $124 0.03% 0 ($34,356)

- 4 ($8,676)

- 0 0.00%

333911 < 500 Employees $305,604 2 $415 0.14% 50 $124 0.04% 0 ($34,356)

- 4 ($8,676)

- 0 0.00%

333923 < 500 Employees $665,645 3 $415 0.06% 33 $124 0.02% 0 ($34,356)

- 3 ($8,676)

- 0 0.00%

333999 < 500 Employees $525,606 2 $415 0.08% 210 $124 0.02% 0 ($34,356)

- 18 ($8,676)

- 0 0.00%

33651 < 1,000 Employees $899,757 0 $415 0.05% 19 $124 0.01% 0 ($34,356)

- 2 ($8,676)

- 0 0.00%

Furniture

and Fixtures 337110 < 500 Employees $96,548 13 $363 0.38% 1,364 $111 0.12% 1 ($27,040)

- 119 ($6,832)

- 0 0.00%

337121 < 500 Employees $142,994 0 $363 0.25% 187 $111 0.08% 0 ($27,040)

- 16 ($6,832)

- 0 0.00%

337122 < 500 Employees $210,111 1 $363 0.17% 487 $111 0.05% 0 ($27,040)

- 42 ($6,832)

- 0 0.00%

337124 < 500 Employees $181,943 0 $363 0.20% 45 $111 0.06% 0 ($27,040)

- 4 ($6,832)

- 0 0.00%

337127 < 500 Employees $212,645 0 $363 0.17% 87 $111 0.05% 0 ($27,040)

- 8 ($6,832)

- 0 0.00%

337211 < 500 Employees $359,656 2 $363 0.10% 62 $111 0.03% 0 ($27,040)

- 5 ($6,832)

- 0 0.00%

337212 < 500 Employees $254,149 1 $363 0.14% 220 $111 0.04% 0 ($27,040)

- 19 ($6,832)

- 0 0.00%

337215 < 500 Employees $319,668 1 $363 0.11% 111 $111 0.03% 0 ($27,040)

- 10 ($6,832)

- 0 0.00%

Auto Dealers (retail trade) 44111 < 200 Employees $1,769,995 0 $352 0.02% 2,917 $109 0.01% 0 ($25,593)

- 254 ($6,476)

- 0 0.00%

44112 < $23 Million

Annual Revenue $626,214 1 $352 0.06% 3,258 $109 0.02% 0 ($25,593)

- 283 ($6,476)

- 0 0.00%

Military

Bases 92812

- - 0 $389

- 0 $119

- 0 ($26,742)

- 0 ($7,495)

- - -

Electronics and Computers 334411 < 750 Employees $134,300 2 $641 0.48% 6 $180 0.13% 0 ($65,304)

- 1 ($16,522)

- 0 0.00%

334412 < 500 Employees $268,086 8 $641 0.24% 83 $180 0.07% 1 ($65,304)

- 7 ($16,522)

- 0 0.00%

334413 < 500 Employees $425,346 30 $641 0.15% 77 $180 0.04% 3 ($65,304)

- 7 ($16,522)

- 0 0.00%

## Exhibit 7

- 1 (continued) Small Business Size Standards, Number of Affected Small Entities, Per

- Facility Costs, Estimated Revenue, and Economic Impact Measure for Industries Affected by the Final Rule a



### 92 Economic Sub

- Sectors with Generators of Solvent

- Contaminated Wipes

Economic

Sub

- Sector s Industries (5

- or 6

- Digit NAICS Code) c, d SBA Size

Standard

for Small

Businesses e Estimated

Revenue for Entity

with One Employee

(2011 Dollars) f LQGs that Use Primarily Reusable Wipes SQGs that Use Primarily Reusable Wipes LQGs that Use Primarily Disposable Wipes SQGs that Use Primarily Disposable Wipes All Generators

Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) i Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) i Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) i Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) h Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities

Over 1% Percent

of

Affected

Small

Enti ties

Over 1%

Transportation

Equipment 332912 < 500 Employees $342,938 0 $350 0.10% 37 $108 0.03% 0 ($25,247)

- 3 ($6,395)

- 0 0.00%

336111 < 1,000 Employees $2,933,702 6 $350 0.01% 16 $108 0.00% 0 ($25,247)

- 1 ($6,395)

- 0 0.00%

336112 < 1,000 Employees $1,533,251 3 $350 0.02% 4 $108 0.01% 0 ($25,247)

- 0 ($6,395)

- 0 0.00%

336211 < 1,000 Employees $526,895 10 $350 0.07% 88 $108 0.02% 1 ($25,247)

- 8 ($6,395)

- 0 0.00%

336312 < 750 Employees $435,006 2 $350 0.08% 107 $108 0.02% 0 ($25,247)

- 9 ($6,395)

- 0 0.00%

33633 < 750 Employees $803,710 2 $350 0.04% 23 $108 0.01% 0 ($25,247)

- 2 ($6,395)

- 0 0.00%

33634 < 750 Employees $563,004 0 $350 0.06% 22 $108 0.02% 0 ($25,247)

- 2 ($6,395)

- 0 0.00%

336399 < 750 Employees $321,211 7 $350 0.11% 142 $108 0.03% 1 ($25,247)

- 12 ($6,395)

- 0 0.00%

336411 < 1,500 Employees $359,948 17 $350 0.10% 16 $108 0.03% 1 ($25,247)

- 1 ($6,395)

- 0 0.00%

336412 < 1,000 Employees $581,014 10 $350 0.06% 30 $108 0.02% 1 ($25,247)

- 3 ($6,395)

- 0 0.00%

336414 < 1,000 Employees $186,489 1 $350 0.19% 0 $108 0.06% 0 ($25,247)

- 0 ($6,395)

- 0 0.00%

336415 < 1,000 Employees $188,950 1 $350 0.19% 0 $108 0.06% 0 ($25,247)

- 0 ($6,395)

- 0 0.00%

336419 < 1,000 Employees $185,908 0 $350 0.19% 5 $108 0.06% 0 ($25,247)

- 0 ($6,395)

- 0 0.00%

336612 < 500 Employees $279,063 11 $350 0.13% 135 $108 0.04% 1 ($25,247)

- 12 ($6,395)

- 0 0.00%

336992 < 1,000 Employees $230,571 1 $350 0.15% 6 $108 0.05% 0 ($25,247)

- 1 ($6,395)

- 0 0.00%

48839 < $7 Million

Annual Revenue $121,153 0 $350 0.29% 63 $108 0.09% 0 ($25,247)

- 5 ($6,395)

- 0 0.00%

54171 < 500 Employees $273,692 6 $350 0.13% 1,543 $108 0.04% 0 ($25,247)

- 134 ($6,395)

- 0 0.00%

81149 < $7 Million

Annual Revenue $93,674 0 $350 0.37% 831 $108 0.12% 0 ($25,247)

- 72 ($6,395)

- 0 0.00%

## Exhibit 7

- 1 (continued) Small Business Size Standards, Number of Affected Small Entities, Per

- Facility Costs, Estimated Revenue, and Economic Impact Measure for Industries Affected by the Final Rule a



### 93 Economic Sub

- Sectors with Generators of Solvent

- Contaminated Wipes

Economic

Sub

- Sector s Industries (5

- or 6

- Digit NAICS Code) c, d SBA Size

Standard

for Small

Businesses e Estimated

Revenue for Entity

with One Employee

(2011 Dollars) f LQGs that Use Primarily Reusable Wipes SQGs that Use Primarily Reusable Wipes LQGs that Use Primarily Disposable Wipes SQGs that Use Primarily Disposable Wipes All Generators

Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) i Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) i Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) i Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities g, h Average

Per

Facility

Costs (2011 Dollars) h Cost

as a
Percent

of

Revenue Number

Affected

Small

Entities

Over 1% Percent

of

Affected

Small

Enti ties

Over 1%

Auto Repair

and

Maintenance 811111 < $7 Million

Annual Revenue $142,100 1 $343 0.24% 8,823 $107 0.08% 0 ($28,944)

- 767 ($6,250)

- 0 0.00%

811112 < $7 Million

Annual Revenue $152,753 0 $343 0.22% 324 $107 0.07% 0 ($28,944)

- 28 ($6,250)

- 0 0.00%



### Economic Sub

- Sectors with Handlers of Solvent

- Contaminated Wipes

Economic

Sub

- Sector Industries (5

- or 6

- Digit NAICS Code) c, d SBA Size

Standard

for Small

Businesses e Estimated

Revenue for Entity

with One Employee

(2011 Dollars) f Handlers of Reusable Wipes Handlers of Disposable Wipes All Handlers

Number Affected

Small Entities g, h Average

Per

- Facility Costs (2011 Dollars) i Cost as a
Percent of

Revenue Number Affected

Small Entities g, h Average

Per

- Facility Costs (2011 Dollars) i Cost as a
Percent of

Revenue Number

Affected

Small

Entities

Over 1% Percent

of

Affected

Small

Entities

Over 1%

Solid Waste Management

Non

- Hazardous

Wastes 562111 < $12.5 Million

Annual Revenue $164,098

- - - 293 ($157)

- 0 0.00%

562212 < $12.5 Million

Annual Revenue $258,634

- - - 348 ($157)

- 0 0.00%

562213 < $12.5 Million

Annual Revenue $175,073

- - - 84 ($157)

- 0 0.00%

562219 < $12.5 Million

Annual Revenue $212,238

- - - 706 ($157)

- 0 0.00%

56292 < $12.5 Million

Annual Revenue $314,032

- - - 1 ($157)

- 0 0.00%

Solid Waste Management

Hazardous

Wastes 562112 < $12.5 Million

Annual Revenue $631,835

- - - 155 ($157)

- 0 0.00%

562211 < $12.5 Million

Annual Revenue $250,991

- - - 644 ($157)

- 0 0.00%

## Exhibit 7

- 1 (continued) Small Business Size Standards, Number of Affected Small Entities, Per

- Facility Costs, Estimated Revenue, and Economic Impact Measure for Industries Affected by the Final Rule a



### 94 Economic Sub

- Sectors with Handlers of Solvent

- Contaminated Wipes

Economic

Sub

- Sector Industries (5

- or 6

- Digit NAICS Code) c, d SBA Size

Standard

for Small

Businesses e Estimated

Revenue for Entity

with One Employee

(2011 Dollars) f Handlers of Reusable Wipes Handlers of Disposable Wipes All Handlers

Number Affected

Small Entities g, h Average

Per

- Facility Costs (2011 Dollars) i Cost as a
Percent of

Revenue Number Affected

Small Entities g, h Average

Per

- Facility Costs (2011 Dollars) i Cost as a
Percent of

Revenue Number

Affected

Small

Entities

Over 1% Percent

of

Affected

Small

Entities

Over 1%

Linen Supply and Laundering 812332 < $35.5 Million

Annual Revenue $208,895 227 $51 0.02%

- - - 0 0.00%



### Total for All Sub

- Sectors

All Affected Small E ntities (Total) 0 0.00%

a The economic impact measure used in this analysis is the compliance cost as a percentage of revenue; [Compliance Cost / Revenue]. The analysis likely overstates impacts because: (1) the incremental per facility cost is based on the

average per

- facility cost for an industry, when in reality, smaller firms generally will incur lower costs under the final rule; (2) revenue per firm i s proxied by revenue per facility, so may be understated; in addition, the analysis scales revenue down to firms with only one emp loyee, even though many or most small entities will have more than one employee and sufficient revenue to support more than o ne employee. In effect, the analysis assumes that all affected small entities are very small, having only one employee and one faci lity. In reality, most affected small entities will have more than one employee, and many affected small entities will have more than one facility (along with greater revenue to support the additional facility(ies)).

b In the exhibit, “

- “ means that the data element is not applicable or available.

c Affected industries (based on five

- or six

- digit NAICS codes) are as reported in Chapter 2 of this document

.

d A ppendix A descri bes each of the NAICS codes in the exhibi t.

e Small Business Administration. Table of Small Business Size Standards Matched to North American Industry Classification System Codes . November 5, 2010. Available at: http://www.sba.gov/sites/default/files/Size_Standards_Table.pdf

, last accessed on December 6, 2011.

f The analysis estimates “ r evenue for entity with one employee” using linear regression on revenue data for entities with between 0 and 60 employees in eac h affected industry. Revenue data were obtained from the following data source: U.S. Census Bureau. “Statistics of U.S. Businesses (SUSB);” 2007 Annual Data; U.S., Six

- Digit NAICS Code. Available at http://www.census.gov/econ/susb/data/susb2007.html , last accessed on December 6 , 2011.

g Total number of small firms for each industry was obtained from the following two data sources: (1) U.S. Census Bureau. “Statistics of U.S. Businesses (SUSB);” 2007 Annual Data; U.S., Six Digit NAICS Code. Available at: http://www.census.gov/econ/susb/data/susb2007.html , last accessed on December 6, 2011

. (2) U.S. Census Bureau. “Statistics of U.S. Businesses (SUSB);” 2007 Annual Data; U.S. all industries data by receipt size. Ava ilable at: http://www.sba.gov/advocacy/849/1 2162#susb , last accessed on December 20, 2011

.

h T he analysis assumes that, within each industry, the percent of small firms affected by the final rule is equal to the percent of facilities that generate (LQGs and SQGs) or handle solvent

- co ntaminated reusable wipes in states that will adopt the final rule, as estimated in Appendix C

.

i Estimation of per

- facility costs is discussed in Chapter 4.

### 95 

## • Identification of a ffected industries

. EPA identified 1 21 industries (based on 5

- or 6

- digit NAICS code) with generators or handlers of solvent

- contaminated wipes , as reported in Chapter 2 of this document

. Exhibit 7

- 1 identifies the affected industries.

• Estimation of the number of affected small entities. The analysis defines small entities based on size standards established by the Small Business Administration (SBA). 144



## These standards define small businesses as firms having less than a specified number of employees or less than a specified level of annual receipts. To estimate the total

number of small firms in each of the 1 21 affected industries, the analysis draws on 2007

SUSB data publish ed by the U.S. Census Bureau. 145

, 146 

## The SUSB provides
information on the number of firms, number of establishments, and estimated receipts (or revenues ), by enterprise employment size and by receipt size (e.g., less than $ 100,000

, $100,000 to 499,000 )

. These data are used to determine the number of small entities in each industry. To estimate the number of small entit ies affected by the final
rule, t he analysis assumes that, within each industry, the percent of small firms affected by the final rule is equal to the percent of facilities that generate (LQGs and SQGs) or
handle solvent

- contaminated wipes in states that w ill adopt the final rule . For example, if 92 percent of facilities in an industry are SQGs that generate solvent

- contaminated

reusable wipes in the states that will adopt the final rule , the analysis assumes that, in that industry, 92 percent of small fir ms are SQGs that generate solvent

- contaminated

reusable wipes in states that will adopt the final rule . Appendix C presents, for each industry, the percent of facilities that generate or handle solvent

- contaminated wipes in

s tates that will adopt the final rule

. Exhibit 7

- 1 provides the SBA small business size

standard and the number of affected small entities for each industry. The analysis

estimates that 57,786 small entities that use or handle solvent

- contaminated wipes are
located in states that will adopt the final rule (i.e., 55,327 generators and 2,458 handlers).

• Estimation of compliance costs. The analysis assumes that small entities incur the

average per

- facility cost for their industry. 147 

## This average per

- facility cost is the same

for all entities (i.e., large and small entities) within an industry. Compliance costs vary for each type of facility (i.e., LQG, SQG, and handling facility) in each of the 1 21 affected

industries. Exhibit 7

- 1 presents th e resulting per

- facility costs for each affected industry

. Using the average per

- facility cost likely will overstate the actual cost for many or most small entities, including in particular the smallest of the small entities that are considered in this analysis (see next bullet). Con sequently, impacts also may be overstated.
Moreover, the analysis evaluates the impact to small entities based on first

- year costs,

which include both annual and first

- year one

- time costs. The u se of first

- year one

- time

costs will overstate the actual co sts for small entities because the first

- year one

- time costs will be spread over the life of the firm. C osts in subsequent years will be less (i.e.,

144 

### Small Business Administration. Table of Small Business Size Standards Matched to North American Industry Classification System Codes . November 5, 2010. Available at: http://www.sba.gov/sites/default/files/Size_Standards_Table.pdf , last accessed on December 6, 2011.

145 

### U.S. Census Bureau. “Statistics of U.S. Businesses (SUSB);” 2007 Annual Data; U.S., Six Digit NAICS

Code. Availa ble at: http://www.census.gov/econ/susb/data/susb2007.html , last accessed on December 6, 2011.

146 

### U.S. Census Bureau. “Statistics of U.S. Businesses (SUSB);” 2007 Annual Data; U.S. all indu stries data by receipt size. Available at: http://www.sba.gov/advocacy/849/12162#susb , last accessed on December 20, 2011.

147 

### In estimating the average per

- facility cost for an industry, the a nalysis applies the methodology described in Chapter 4 of this document.

### 96 

## they do not include the first

- year one

- time costs ). Therefore, economic impacts in subsequent years will be reduced.

• Estimation of total revenue. Financial information is not available on every firm that is going to be affected by the final rule. Therefore, in evaluating the impacts of the final rule on small entities, the analysis uses distributional data on firm revenue for each industry. The analysis obtained revenue data for each of the 1 21 affected industries from the 2007 SUSB data published by the U.S. Census Bureau. 148 

## Estimated revenues have been updated to 2011 dollars using GDP deflators developed by the U.S. Department of Commerce. 149 

## U sing the updated r evenue data, the analysis then used a linear regression model to estimate small entity total revenue as a function of the number of employees. Exhibit 7

- 1 reports the estimated revenue for the smallest of the

small entities , firms with o ne employee. Firms with one employee are used to analyze the impacts on small entities because they are they are the smallest of the small entities.

F irms with more than one employee would be expected to have higher revenue and, therefore, smaller impacts. Bas ed on the analysis o f firms with one employee will

overstat e the economic impacts on small entities

.

• Evaluation of impacts. The analysis estimates the compliance cost under the final rule as a percentage of an entity’s total revenue for e ach type of facility (i.e., LQGs, SQGs, and handling facilities) in the 1 21 affected industries. To derive this measure, the analysis divides the per

- facility compliance costs by the total revenue of firms with one

employee. Exhibit 7

- 1 presents the resulting economic impact measures for each affected industry.

As shown in Exhibit 7

- 1, costs of the final rule expressed as a percentage of revenue for the

small est of small entities ( firms with only one employee )

, range from only 0.0 02 percent to 0. 5 3 7
percent. 150 

## These results are well below the one percent screening criterion used to identify firms that might experience significant economic impacts. Small entities that have more than one employee generally will have higher revenues and smaller econom ic impacts compared to firms with one employee

. Based on this screening analysis, the majority of the firms are not expected to face significant economic impacts as a result of the final rule; this analysis

concludes that the final rule will not result in significant economic impacts on a substantial

number of small entities.

Note that this analysis is likely to overstate the impacts of the final rule on small entities in the following ways: (1) use of average per

- facility costs for an industry will over state costs for most small firms which are likely to have smaller operations and smaller costs than large firms ; (2) use of first

- year costs (which include one

- time costs as well as annual costs) will overstate

costs and impacts in subsequent years); (3) the analysis is sensitive to the smallest of the small

148 

### U.S. Census Bureau. “ Statistics of U.S. Businesses (SUSB); ” 2007 Annual Data; U.S., Six

- D igit NAIC S

Code. Available at : http://www.census.gov/econ/susb/data/susb2007.html , last accessed on December 6 , 2011.

149 

### U.S. Department of Commerce, Bureau of Economic Analysis

. “ Table 1.1.9. Implicit Price Deflators for

Gross Domestic Product

. ” Available online at: http://www.bea.gov/national/nipaweb/TableView.asp?SelectedTable=13&Freq=Qtr&FirstYear=2006&LastYear=2008

, last accessed on November 6 , 2011

. Year 2007, Quarter IV = 106.958 and Y ear 2011, Quarter III = 113.823

.

150 

### The analysis only considers entities that will incur costs as a result of the final rule. For those entities that will benefit from the final rule in the form of cost savings, th ey were not factored into the analysis to assess the economic impact on small entities.

### 97 

## entities (i.e., one

- employee firms), given that many or most affected small entities will have more employees and thus, the higher levels of revenue needed to support more employees.



## 7.2. Executive Order 12 630 : Regulatory Takings Analysis

The final rule does not constitute a regulatory taking because it is not expected to result in the physical invasion of property and should not negatively impact the economic viability of
property.



## 7.3. Executive Order 12988: Civil Justice Reform

The final rule specifies in clear language the effect of the regulation; specifies its relationship to the provisions of other laws; incorporates clear legal standards; has no retroactive effect; and defines key terms. Therefore, no additional analysis or actions are required under Executive

Order 12988.



## 7.4. Executive Order 12898: Federal Actions to Address Environmental Justice in Minority Populations and Low

- Income Populations

Executive Order 12898 (59 FR 7629; 60 FR 6381), “Federal Actions to Address Environmental Justice in Minority Populations and Low

- Income Populations,” requires Federal agencies to “make achieving environmental justice part of its mission by identifying and addressing, as appropriate, disproportio nately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low

- income populations...”

In response to Executive Order 12898, EPA developed an environmental justice (EJ)
strategy. 151 

## Th e purpose of the strategy is to ensure the integration of EJ into EPA’s programs, policies, and activities consistent with the Executive Order. As stated in the strategy, EPA’s goals are to ensure that no segment of the population, regardless of race, col or, national origin, or income suffers disproportionately from adverse human health or environmental effects as a result of EPA’s policies, programs, and activities; and that all people live in clean, healthy, and

sustainable communities.

The methodology for evaluating the potential for disproportionate adverse impacts to minority

and low

- income populations as a result of a rulemaking consists of two parts. First, the Agency evaluates the potential for adverse impacts to any populations as a result of a r ulemaking. Second, if there is a potential for adverse impacts, then EPA evaluates whether those impacts would disproportionately affect minority and/or low

- income populations.

In evaluating the potential impacts of the solvent

- contaminated wipes final rule, EPA has determined that there are no potential adverse impacts to any populations. Therefore further analysis is not required because there would also be no potential adverse impacts to minority or

low

- income populations.

151 

### U.S. Environmental Protection Agency. The EPA's Environmental Justice Strategy. April 3, 1995.

Available at: http://www.epa.gov/environmentaljustice/resources/policy/ej_strategy_1995.pdf , last accessed on
December 9, 2011.

### 98 

## Potential for Adverse Impacts

Hazardous waste solvents can pose a potential hazard to human health and the environment.

When EPA listed the F001

- F005 spent solvents , as well as the corresponding P

- or U

- listed

solvents as hazardous waste, the Agency det ermined that they pose significant risk to human health and the environment due to their toxicity, and/or ignitability.

However, EPA does not anticipate that solvent

- contaminated wipes subject to the final rule will adversely impact human health and the e nvironment for several reasons. First, the solvent

contaminated wipes (whether sent for disposal or recycling) must contain "no free liquids" (using the Paint Filter Liquids Test, or other similar tests as required by the states) prior to be transported o ff

- site. Additionally, the container the solvent

- contaminated wipes are transported in also must not contain free liquid prior to transport off

- site. Thus, the amount of actual solvent that is transported, whether for disposal or recycling/reuse, will be minimal and reduce the hazards from releases of “free liquids,” fugitive air emissions, fires, and explosions. (Note: Free liquids that are removed the solvent

- contaminated wipes or containers that hold the solvent

contaminated wipes must be managed in ac cordance with the applicable hazardous waste regulations found in 40 CFR parts 260 through 273.) Next, for solvent

- contaminated wipes disposed in a landfill, they must be sent to a landfill that is subject to the standards under 40 CFR Part 258, including 40 CFR 258.40 (i.e., a municipal solid waste landfill). (In developing these standards, the Agency recognized that hazardous wastes from CESQGs would also being sent to such landfills, and thus, the specific standards reflect the acceptance of such hazar dous wastes.) The design criteria at 40 CFR 258.40 include requirements that landfills be lined, or that they have an approved design that is protective of the uppermost aquifer. The risk analysis

conducted for this final rule also demonstrates that there is no significant risk to human health and the environmental from groundwater contamination from eligible solvent

- contaminated wipes disposed in these landfills under the final rule. 152 Similarly, solvents that are sent for burning must go a combustor regula ted under section 129 of the Clean Air Act or operating under 40 CFR 264 or 265, which address potential risks from air emissions

. Finally, solvent

contaminated wipes intended for laundering or dry cleaning must go to an industrial laundry or a dry cleane r whose discharges, if any, are regulated under sections 402 and section 307(b) of the Clean Water Act, to address potential risks to surface waters.

Furthermore, EPA anticipates that additional conditions of the final rule will help reduce adverse

human health and environmental effects that sometimes result from the mismanagement of

solvent

- contaminated wipes:

• Wipes must be stored in non

‐ leaking, closed containers. This condition ensures that the wipes are contained and are not exposed to the environment (and potential ignition sources).

• Wipes must be labeled "Exempt Solvent

‐ Contaminated Wipes." This condition ensures that the generator, transporter, and handle r are aware of the contents of the containers and can handle them appropriately.

Finally, EPA anticipates that the final rule will not adversely affect transportation risk. In the case of disposable wipes, they will need to be transported to municipal so lid waste landfills or

152 

### Solvent

- contaminated wipes risk analysis documents are available from www.regulations.gov in docket

under Docket ID No. EPA

- HQ

- RCRA

- 2003

- 0004

.

### 99 

## solid waste combustion units under the rule instead of hazardous waste facilities. Municipal solid waste landfills and solid waste combustion units are expected to be closer to generators of

solvent

- contaminated wipes because they a re more numerous. Because solvent

- contaminated wipes are expected to be transported over shorter distances under the rule, overall hazards associated with transportation are expected to decrease as the total vehicle miles traveled for trucks carrying the solvent

- contaminated wipes decreases

In addition, EPA anticipates that fewer trips will be needed to transport solvent

- contaminated wipes under the rule. When disposed of as hazardous waste, solvent

- contaminated wipes would likely be transported within 9 0 days of generation by large quantity generators, and 180 days by small quantity generators, and then must be transported by a licensed hazardous waste transporter, which may require special trips at less than truckload capacity. When disposed of

as munic ipal solid waste, the disposable wipes are likely to present only an incremental addition to the total amount of municipal solid waste disposed, and not present a need for special or additional trips, reducing the total number of truck trips and vehicle mi les travelled and not affecting the overall impact of the well established solid waste hauler routes.

Conclusion

Based on the above information, EPA believes that there will be no adverse impacts to human

health and the environment as a result of the final rule, and that in most cases, hazards

associated with solvent

- contaminated wipes will be reduced for all population. Therefore, EPA

there would not be disproportionately high and adverse human health or environmental impacts on minority populations and low

- income populations from the final rule.



## 7.5. Exe cutive Order 13045: Protection of Children from Environmental Health Risks and Safety Risks

Exe cutive Order 13045 (62 FR 19885; 68 FR 19931 ) , “ Protection of Children from

Environmental Health Risks and Safety Risks ,” applies to any rule that : ( 1) is determined to be ‘‘economically significant’’ as defined under Executive Order 12866 ( Regulatory Planning and

Review ) , and (2) concerns an environmental health risk or safety risk that an agency has reason to believe may disproportionately affect children. If the regulatory action meets both criteria, the

a gency must evaluate the environmental health or safety effects of the planned regulation on children, and explain why the planned regulation is preferabl e to other potentially effective and reasonably feasible alternatives considered by the a gency.

The final rule is not subject to Executive Order 13045 because it is not an economically significant regulatory action as defined in Executive Order 12866, an d because EPA does not

have reason to believe the environmental health risks or safety risks addressed by the final rule
present a disproportionate risk to children. As discussed in Section 7.2, t his final rule applies to

industrial launderers , and generators and handlers of solvent

- contaminated wipes . Therefore, it is not expected to increase exposure of solvents to the general public (i.e., adults or children )

.



## 7.6. Unfunded Mandate Reform Act (UMRA)

Title II of the Unfunded Mandates Reform Act of 1 995 (UMRA), Pub. L. 104

– 4, establishes requirements for F ederal agencies to assess the effects of their regulatory actions on s tate, local, and t ribal governments

, and the private sector. Under S ection 202 of the UMRA, Federal agencies must prepare a writ ten statement for proposed and final rules that include any

### 100 

## “Federal mandate” that may result in expenditures by s tate, local, and t ribal governments, in the
aggregate, or by the private sector, of $100 million or more in any one year.

Before a Federal regulatory agency promulgates a rule for which a written statement is needed

, Section 205 of the UMRA requires the Federal agency to identify and consider a reasonable

number of regulatory alternatives and , from those alternatives, adopt the least costly, most cost

effective, or least burdensome alternative that achieves the objectives of the rule. The provisions of S ection 205 do not apply when they are inconsistent with applicable law. Moreover, S ection 205 allows the Federal agency t o adopt an alternat ive other than the least costly, most cost

- effective, or least burdensome alternative if the head of the agency publishes

with the final rule an explanation of why that alternative was not adopted.

Before establishing any regulatory requirements that mig ht significantly or uniquely affect small
governments, Federal agencies must have developed , under Section 203 of the UMRA, a small government agency plan

. The plan must provide for notifying potentially affected small
governments ; enabling officials of affected small governments to provide meaningful and timely input in the development of regulatory proposals containing significant Federal intergovernmental mandates; and informing, educating, and advising small governments on compliance with the regulato ry requirements.

Under the final rule, EPA is modifying its hazardous waste management regulations under

RCRA to: (1) conditionally exclude from the definition of solid waste solvent

- contaminated

reusable wipes and (2) conditionally exclude from the defi nition of hazardous waste solvent

contaminated disposable wipes . The conditional exclusions are considered less stringent than

the current F ederal regulations because they exclude certain materials now regulated by RCRA subtitle C. Thus, a uthorized s tate s are not required to adopt the final rule , provided their program is at least as stringent as the Federal program

. In addition, even if the final rule is adopted by their s tate, generators of solvent

- contaminated wipes may opt to continue to manage solve nt

- contaminated wipes under current Federal hazardous waste regulations rather than under the conditional exclusions. Therefore, the final rule does not contain Federal mandates (under the provisions of Title II of the UMRA) for s t ate, local, or t ribal governments, or the private sector.

In addition, EPA has determined that the final rule contains no regulatory requirements that might significantly or uniquely affect small governments. Furthermore, as analyzed in Chapter 6

of this document , t he final rule will not result in expenditures by s tate, local, and t ribal governments, in the aggregate, or by the private sector, of $100 million or more in any one year.

Based on the information above

, the final rule is not subject to the requirements of S ections

202 , 203, or 205 of the UMRA.

### 101 

## 7.7. Executive Order 13132: Federalism

Executive Order 13132 (64 FR 43255 ), “Federalism,” requires Federal agencies to develop an accountable process to ensure ‘‘meaningful and timely input by s tate and local officials in the development of regulatory policies that have f ederalism implications.’’ ‘‘Policies that have federalism implications’’ is defined in the Executive Order to include regulations that have

‘‘substantial direct effects on the s tates, on the relationship between the national government

and the s tates, or on the distribution of power and responsibilities among the various levels of government.’’

Executive Order 13132 instructs Federal agencies to take national action limiting the policymaking discretion of the s tates “only when there is constitutional and statutory authority for the action and the national activity is appropriate in light of the presence of a probl em of national significance.” With respect to preemption, Federal agencies shou ld “ construe a Federal statute
to preempt s tate law only where the statute contains an express preemption provision or there is some other clear evidence that Congress i nt ended preemption of s tate law, or where the

exercise of s tate authority conflicts wit h the exercise of Federal authority under the Federal

statute.” “ Any regulatory preemption of s tate law must be restricted to the minimum level necessary to achieve the objectives of the statute pursuant to which the regulations are promulgated. ”

The Res ource Conservation and Recovery Act (RCRA, 42 U.S.C. 6901 to 6992k ) establishes

the relationship between s tates and the national government with respect to hazardous waste
management , including provisions for a uthorized s tate hazardous waste programs ( 42 U .S.C. 6926, S ection 3006) and retention of s t ate authority (42 U.S.C. 6929, S ection 3009). Under

S ection 3009 of RCRA, s tates and their political subdivisions may not impose requirements less stringent for hazardous waste management than the national government. Therefore

, although

the final rule pre v e n t s s tate and local law s that are less stringent with respect to management of

solvent

- contaminated wipes, the final rule does not have federalism implications beyond those already established by RCRA

. It will not have sub stantial direct effects on the s tates, on the relationship between the national government and the s tates, or on the distribution of power and responsibilities among the various levels of government, as specified in Executive Order 1313 2.



## 7.8. Executive Order 13175: Consultation and Coordination with Indian Tribal

Governments

Executive Order 13175 (65 FR 67249 ), “ Consultation and Coordination with Indian Tribal

Governments ,” requires Federal agencies to develop an accountable process to ensure

“ meaningful and timely input by t ribal officials in the development of regulatory policies that h ave

t ribal implications.” “P olicie s that have t ribal implications” is defined in the Executive Order to

include regulations that have “ substantial dir ect effects on one or more Indian t ribes, on the

re lationship between the Federal Government and Indian t ribes, or on the distribution of power and respon sibilities between the Federal G overnment and Indian t ribes. ”

EPA has concluded that this action ma y have tribal implications to the extent that generating facilities on tribal lands use solvents on wipes or handling facilities located on tribal lands may

receive solvent

- contaminated wipes. However, it will neither impose substantial direct compliance c osts on tribal governments, nor preempt Tribal law.

### 102 

## 7.9. Executive Order 13211: Actions That Significantly Affect Energy Supply,

Distribution, or Use

Executive Order 13211 (66 FR 28355) , “Actions Concerning Regulations That Significantly Affect Energy Supply, Distribution, or Use,” requires federal agencies to prepare a “Statement of Energy Effects” when undertaking certain regulatory actions. A Statement of Energy Effects describes the adverse effects of a “significant energy action” on energy supply, distribution and use, reasonable alternatives to the action, and the expected effects of the alternatives on energy supply, distribution and use. A significant energy action is an action that “promulgates or is expected to lead to the promulgation of a fi nal rule or regulation” (and normally published in the Federal Register), including notices of inquiry, advance notices of proposed rulemaking, and notices of proposed rulemaking, and that is: 1) a significant regulatory action under Executive

Order 12866 (or successor order) that is likely to have a significant adverse effect on the supply, distribution, or use of energy (see next section for determining “significant adverse energy effect”); or 2) is designated by the Administrator of the Office of Informa tion and Regulatory Affairs as a significant energy action.

This action is not a “significant energy action” as defined in Executive Order 13211 (66 FR 28355 (May 22, 2001)), because it is not likely to have a significant adverse effect on the supply, distribution, or use of energy. This final rule reduces net regulatory burden and may possibly induce fuel efficiency and energy savings from the voluntary shifting of solvent

contaminated wipes from more distantly located RCRA permitted hazardous waste la ndfills and combustors to more closely located MSWLFs and combustors, where it is cost effective to do so. It therefore should not adversely affect energy supply, distribution, or use.



## 7.10. Executive Order 13352: Facilitation of Cooperative Conservation

Exec utive Order 13352 (69 FR 52989), “Facilitation of Cooperative Conservation,” requires specified Federal agencies, including EPA, to carry out the activities relating to the environment and natural resources in a manner that: facilitates cooperative conser vation, considers interests of landowners and others with interest in land and other natural resources, accommodates local participation, and considers protection of public health and safety.

The final rule is designed to promote cooperative conservation of the environment and n atural resources between EPA, state, and local governments by identifying clear criteria for the appropriate management of solvent

- contaminated wipes, while maintaining protection of human

health and the environment.

### March 16, 2012 DRAFT A

- 1 

## Ap pendix A Description of North American Industry Classification System (NAICS)

Codes Associated with Industries that May Be Affected by the Final Rule

Generators of Solvent

- Contaminated Wipes

**Printing**

323110 Commercial Lithographic Printing

323111 Commercial Gravure Printing

323112 Commercial Flexographic Printing

323113 Commercial Screen Printing

323114 Quick Printing

323115 Digital Printing

323116 Manifold Business Forms Printing

323117 Books Printing

323118 Blankbook, Looseleaf Binders, and Devices Manufacturing

323119 Other Commercial Printing

323121 Tradebinding and Related Work

323122 Prepress Services

**Publishing (printed matter)** 

51111 Newspaper Publishers

51112 Periodical Publishers

51113 Book Publishers

51114 Directory and Mailing List Publishers

51119 Other Publishers

**Business services (copy shops)**

561439 Other Business Service Centers (including Copy Shops)

**Chemical a nd Allied Products** 

211112 Natural Gas Liquid Extraction

32511 Petrochemical Manufacturing

32512 Industrial Gas Manufacturing

325131 Inorganic Dye and Pigment Manufacturing

325132 Synthetic Organic Dye and Pigment Manufacturing

325181 Alkalies and Chlorine Manufacturing

325182 Carbon Black Manufacturing

325188 All Other Basic Inorganic Chemical Manufacturing

325191 Gum and Wood Chemical Manufacturing

325192 Cyclic Crude and Intermediate Manufacturing

325193 Ethyl Alcohol Manufacturing

325199 All Other Basic Organic Chemical Manufacturing

325998 All Other Miscellaneous Chemical Product and Preparation Manufacturing

331311 Alumina Refining

**Plastics and Rubber**

31332 Fabric Coating Mills

315299 All Other Cut and Sew Apparel Manufacturing

315999 Other Apparel Acc essories and Other Apparel Manufacturing

325991 Custom Compounding of Purchased Resins

326113 Unlaminated Plastics Film and Sheet (except Packaging) Manufacturing

326121 Unlaminated Plastics Profile Shape Manufacturing

32613 Laminated Plastics Plate, Sheet (except Packaging), and Shape Manufacturing

32614 Polystyrene Foam Product Manufacturing

32615 Urethane and Other Foam Product (except Polystyrene) Manufacturing 32616 Plastics Bottle Manufacturing

326191 Plastics Plumbing Fixture Manufacturing

326192 Res ilient Floor Covering Manufacturing

326199 All Other Plastics Product Manufacturing

326211 Tire Manufacturing (except Retreading)

32622 Rubber and Plastics Hoses and Belting Manufacturing

326291 Rubber Product Manufacturing for Mechanical

Use

326299 All Ot her Rubber Product Manufacturing

337215 Showcase, Partition, Shelving, and Locker Manufacturing

339113 Surgical Appliance and Supplies Manufacturing

339932 Game, Toy, and Children's Vehicle Manufacturing

339991 Gasket, Packing, and Sealing Device

Manufactu ring

**Fabricated Metal Products**

332812 Metal Coating, Engraving (except Jewelry and Silverware), and Allied Services to

Manufacturers

332813 Electroplating, Plating, Polishing, Anodizing, and Coloring

339911 Jewelry (except Costume) Manufacturing

339912 Silverware and Hollowware Manufacturing

339914 Costume Jewelry and Novelty Manufacturing

**Industrial Machinery and Equipment**

314999 All Other Miscellaneous Textile Product Mills

332323 Ornamental and Architectural Metal Work Manufacturing

33241 Power Boile r and Heat Exchanger Manufacturing

332991 Ball and Roller Bearing Manufacturing

333111 Farm Machinery and Equipment Manufacturing

33312 Construction Machinery Manufacturing

33322 Plastics and Rubber Industry Machinery Manufacturing

333295 Semiconductor Mac hinery Manufacturing

333298 All Other Industrial Machinery Manufacturing

333319 Other Commercial and Service Industry Machinery Manufacturing

333414 Heating Equipment (except Warm Air Furnaces) Manufacturing

333511 Industrial Mold Manufacturing

333512 Mach ine Tool (Metal Cutting Types) Manufacturing

333513 Machine Tool (Metal Forming Types) Manufacturing

333514 Special Die and Tool, Die Set, Jig, and Fixture Manufacturing

333515 Cutting Tool and Machine Tool Accessory Manufacturing

333518 Other Metalworking Machinery Manufacturing

333911 Pump and Pumping Equipment Manufacturing

333923 Overhead Traveling Crane, Hoist, and Monorail System Manufacturing

333999 All Other Miscellaneous General Purpose Machinery Manufacturing

33651 Railroad Rolling Stock Manufacturing

## Appendix A (continued) Description of North American Industry Classification System (NAICS)

Codes Associated with Industries that May Be Affected by the Final Rule

March 16, 2012 DRAFT C

- 2 **Furniture and Fixtures**

337110 Wood Kitchen Cabinet and Countertop Manufacturing

337121 Upholstered Household Furniture Manufacturing

337122 Nonupholstered Wood Household Furniture Manufacturing

337124 Metal Household Furniture Manufacturing

337127 Institutional Furniture Manufacturing

337211 Wood Office Furniture Manufacturing

337212 Custom Architectural Woodwork and Millwork Manufacturing

337215 Showcase, Partition, Shelving, and Locker Manufacturing

**Auto Dealers (retail trade)**

44111 New Ca r Dealers

44112 Used Car Dealers

**Military Bases**

92812 International Affairs

**Electronics and Computers**

334411 Electron Tube Manufacturing

334412 Bare Printed Circuit Board Manufacturing

334413 Semiconductor and Related Device Manufacturing

**Transportation Equipment** 

332912 Fluid Power Valve and Hose Fitting Manufacturing

336111 Automobile Manufacturing

336112 Light Truck and Utility Vehicle Manufacturing

336211 Motor Vehicle Body Manufacturing

336312 Gasoline Engine and Engine Parts Manufacturing

33633 Moto r Vehicle Steering and Suspension Components (except Spring) Manufacturing

33634 Motor Vehicle Brake System Manufacturing

336399 All Other Motor Vehicle Parts Manufacturing

336411 Aircraft Manufacturing

336412 Aircraft Engine and Engine Parts Manufacturing

336414 Guided Missile and Space Vehicle Manufacturing

336415 Guided Missile and Space Vehicle Propulsion Unit and Propulsion Unit Parts Manufacturing

336419 Other Guided Missile and Space Vehicle Parts and Auxiliary Equipment Manufacturing

336612 Boat Bui lding

336992 Military Armored Vehicle, Tank, and Tank Component Manufacturing

48839 Other Support Activities for Water Transportation

54171 Research and Development in the Physical, Engineering, and Life Sciences

81149 Other Personal and Household Goods Re pair

and Maintenance

**Auto Repair and Maintenance**

811111 General Automotive Repair

811112 Automotive Exhaust System Repair Handlers of Solvent

- Contaminated Wipes

**Solid Waste Management**

**– Hazardous Wastes** 

562112 Hazardous Waste Collection

562211 Hazardous Waste Treatment and Disposal

**Solid Waste Management**

**– Non Hazardous Wastes** 

562111 Solid Waste Collection

562212 Solid Waste Landfill

562213 Solid Waste Combustors and Incinerators

562219 Other Nonhazardous Waste Treatment and Disposal

56292 Materials Recovery Facilities

**Linen Supply and Laundering**

812332 Industrial Launderers

### March 16, 2012 DRAFT B

- 1 

## Appendix B

Information on State Waste Fees and Taxes

State Hazardous Waste Management State Hazardous Waste

Fees and Taxes State Non

- Hazardous Waste

Fees and Taxes

Data Source(s) Management Generation Management

Tons Managed in

Landfill Tons Managed in

Incinerator Disposal ($/ton) Incineration ($/ton) ($/ton) Disposal ($/ton) Incineration ($/ton)

Alabama 78,668 8,973 $71.60 $0.00 $0.00 $1.00 $0.00 (1) Alabama Department of Revenue. "Frequently Asked Questions" Web Site, "Hazardous Waste Fees" and "Solid Waste Disposal Fees." Available at: http://www.ador.state.al.us/tobaccotax/faqtt.html#waste, last accessed on November 15, 2011. Average of disp osal fees for hazardous waste, P

- listed wastes, and U

- listed wastes at management facilities other than the Emelle, Alabama facility. (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Condi tional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

Alaska 202 229 $0.00 $0.00 $0.00 $0.00 $0.00 (1) U.S. Army Corps of Engineers, HTRW Center of Expertise Information

- TSDF. Report on
Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 2006 Update, "Section 13

- State Taxes and Fees." Available at: http://www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last accessed on November 15,

2011. (2) U.S. Env ironmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

Arizona 29,280 4,115 $40.00 $0.00 $10.00 $0.00 $0.00 (1) Arizona Department of Environmental Quality. "Draft Hazardous Waste Fees as authorized by HB 2705." Available at: http://www.azdeq.gov/environ/waste/download/061411dhwf.pdf ,
last accessed on November 15, 2011. (2) U.S. Environme ntal Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

Arkansas 49,425 4,711 $11.00 $3,000.00 $0.00 $0.00 $0.00 (1) Arkansas Pollution Control and Ecology Commission. Regulation No. 23

- Hazardous Waste Management , Section 6

- Fees and Costs. Available at: http://www.adeq.state.ar.us/regs/files/reg23_final_110926.pdf, last accessed on November 15,

201 1. Fee on generation of hazardous waste based on Category 2, 30,000 pounds to 99,999 pounds (i.e., 15 tons to 49.99 tons). (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exc lusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. July 17, 2003. p.169.

## Appendix B (continued)

Avoided State Waste Fees and Taxes

March 16, 2012 DRAFT C

- 2 State Hazardous Waste Management State Hazardous Waste

Fees and Taxes State Non

- Hazardous Waste

Fees and Taxes

Data Source(s) Management Generation Management

Tons Managed in

Landfill Tons Managed in

Incinerator Disposal ($/ton) Incineration ($/ton) ($/ton) Disposal ($/ton) Incineration ($/ton)

California 100,112 52,131 $49.95 $5.58 $0.00 $20.16 $5.58 (1) California Department of Toxic Substances Control. "Department of Toxic Substances

Control Fee Summary

- Effective January, 2011;" "TABLE 3: Land Disposal Fees for CY 2011"

and "TABLE 10: Generator Fee CY 2011." Available at: http://www.dtsc.ca.gov/IDManifest/2011_Fee_Summary.cfm#c, last accessed November 15,

2011. Gene ration fee based on genera tor s ize "0 but less than 250 tons/year." (2) U.S. Environmental Protection Agency. E conomics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

Colorado 5,186 10,978 $9.92 $7.09 $0.00 $5.25 $7.09 Colorado Department of Public Health and Environment. "Solid and Hazardous Waste Commission Regulations 6 CCR 1007

- 3," "Part 100

- Permit Regulations" and "Part 262

- Standards Applicable to Generators of HW." Available at: http://www.cdphe.state.co.us/regulations/hazwaste/, last accessed on November 15, 2011. Annual generation fee based on LQG fee.

Connecticut 3,048 4,214 $15.00 $15.00 $9.60 $0.50 $0.00 U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

Delaware 746 2,624 $21.00 $4.00 $0.00 $0.00 $0.00 (1) State of Delaware. "Delaware Online Code" Web site, "Delaware Code of Regulations,"

TITLE 7

- Conservation, Natural Resources," "Chapter 63

- Hazardous Waste Management," " Subchapter II

- Miscellaneous Provisions," "Section 6319(f) ." Available at: http://delcode.delaware.gov/title7/c063/sc02/index.shtml, last accessed on November 15, 2011. (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of S olvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

District of

Columbia 416 7 $0.00 $0.00 $0.00 $0.00 $0.00 (1) U.S. Army Corps of Engineers, HTRW Center of Expertise Information

- TSDF. Report on Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 2006 Update, "Section 13

- State Taxes and Fees." Available at: http://www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last accessed on November 15,

2011. (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

## Appendix B (continued)

Avoided State Waste Fees and Taxes

March 16, 2012 DRAFT C

- 3 State Hazardous Waste Management State Hazardous Waste

Fees and Taxes State Non

- Hazardous Waste

Fees and Taxes

Data Source(s) Management Generation Management

Tons Managed in

Landfill Tons Managed in

Incinerator Disposal ($/ton) Incineration ($/ton) ($/ton) Disposal ($/ton) Incineration ($/ton)

Florida 4,367 4,616 $0.00 $0.00 $0.00 $0.00 $0.00 (1) U.S. Army Corps of Engineers, HTRW Center of Expertise Information

- TSDF. Report on Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 2006 Update, "Section 13

- State Taxes and Fees." Available at: http: //www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last accessed on November 15,

2011. (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

Georgia 15,135 22,500 $23.00 $23.00 $0.00 $0.00 $0.00 (1) Georgia Department of Natural Resources. Guidelines for Calculating Hazardous Waste Management Fees and Hazardous Substance Reporting Fees , "Section 2.3.2

- Large Quantity Generators (LQG); Calculation of the Hazardous Waste Management Fees." Available at: http://www.georgiaepd.org/Files_PDF/forms/hwb/fee_guide.pdf, last accessed on November 15,

2011. (2) U.S. Environmental Protectio n Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

Hawaii 48 166 $0.00 $0.00 $0.00 $0.00 $0.00 (1) U.S. Army Corps of Engineers, HTRW Center of Expertise Information

- TSDF. Report on Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 2006 Update, "Section 13

- State Taxes and Fees." Available at: http:/ /www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last accessed on November 15,

2011. (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

Idaho 6,825 1,545 $30.00 $30.00 $0.00 $0.00 $0.00 (1) State of Idaho. Idaho Code of Regulations , "Title 39

- Health and Safety, " "Chapter 44

- Hazardous Waste Management, " "Section 39

- 4427

- Commercial Disposal Fees." Available at: http://www.legislature.idaho.gov/idstat/Title39/T39CH44SECT39

- 4427.htm, last accessed on
November 15, 2011. (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of

National Economi c Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

Illinois 40,444 15,791 $61.00 $20.00 $0.00 $0.95 $0.00 U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

## Appendix B (continued)

Avoided State Waste Fees and Taxes

March 16, 2012 DRAFT C

- 4 State Hazardous Waste Management State Hazardous Waste

Fees and Taxes State Non

- Hazardous Waste

Fees and Taxes

Data Source(s) Management Generation Management

Tons Managed in

Landfill Tons Managed in

Incinerator Disposal ($/ton) Incineration ($/ton) ($/ton) Disposal ($/ton) Incineration ($/ton)

Indiana 196,654 24,710 $11.50 $11.50 $0.00 $0.00 $0.00 (1) State of Indiana. "Information Maintained by the Office of Code Revision Indiana Legislative Services Agency" Web site, "IC 13

- 22

- 12

- 2, Fee Schedule; Application Fees." Available at: http://www.state.in.us/legislative/ic/code/title13/ar22/ch12.html, last accessed on November 15,

2011. (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

Iowa 30,937 6,961 $40.00 $0.00 $50.00 $0.00 $0.00 (1) Iowa Department of Natural Resources. "Iowa Department of Natural Resources Hazardous

Waste Activities Form." Available at: http://www.iowadnr.gov/portals/idnr/uploads/consites/hwfeeform.pdf?amp;tabid=698, last

accessed on Novembe r 15, 2011. (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. July 17, 2003. p. 169.

Kansas 5,839 4,006 $10.00 $20.00 $0.00 $0.00 $0.00 (1) Kansas Department of Health and Environment, Bureau of Waste Management. "Hazardous Waste Fees." http://www.kdheks.gov/waste/p_hwfees.html, last accessed on November 15, 2011. Based on generator fee for "greater than 50 tons but less than or equal to 500 tons"
category. (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Reg ulation . July 17, 2003. p. 169.

Kentucky 3,525 13,921 $24.10 $12.05 $10.50 $0.00 $0.00 U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

Louisiana 30,357 19,032 $85.00 $0.00 $0.00 $0.00 $0.00 U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

Maine 914 188 $40.00 $30.00 $0.00 $0.00 $0.00 U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

## Appendix B (continued)

Avoided State Waste Fees and Taxes

March 16, 2012 DRAFT C

- 5 State Hazardous Waste Management State Hazardous Waste

Fees and Taxes State Non

- Hazardous Waste

Fees and Taxes

Data Source(s) Management Generation Management

Tons Managed in

Landfill Tons Managed in

Incinerator Disposal ($/ton) Incineration ($/ton) ($/ton) Disposal ($/ton) Incineration ($/ton)

Maryland 17,231 6,082 $0.00 $0.00 $0.00 $0.00 $0.00 (1) U.S. Army Corps of Engineers, HTRW Center of Expertise Information

- TSDF. Report on Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 2006 Update, "Section 13

- State Taxes and Fees." Available at: http://www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last accessed on November 15,

2011. (2 ) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

Massachusetts 2,233 4,723 $0.00 $0.00 $0.00 $0.00 $0.00 (1) Massachusetts Department of Environmental Protection. "Service Center" Web site, "Fees, Billing & Timelines ," Annual Compliance Fees." Available at: http://www.mass.gov/dep/service/acfees.pdf, last accessed on November 15, 2011. Hazardous waste generation fee based on LQG fee. (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA

Hazardous Waste Re gulation . July 17, 2003. p. 169.

Michigan 15,544 20,414 $10.00 $10.00 $0.00 $0.00 $0.00 (1) Michigan Department of Environmental Quality. "Hazardous Waste User Charges and Invoice Packets." Available at: http://www.michigan.gov/deq/0,4561,7

- 135

- 3312_4118_4240

- 47207

-- ,00.html, last accessed on November 16, 2011. Hazardous waste generation fee based

on LQG fee. (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

Minnesota 7,489 9,725 $77.11 $19.28 $0.00 $0.45 $0.00 U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation

. July 17, 2003. p. 169.

Mississippi 3,495 17,894 $10.00 $2.00 $0.00 $1.00 $1.00 (1) State of Mississippi. "Mississippi Code of 1972," "Section 49

- 31

- 25

- Pollution Prevention Fee; Penalty for Failure to Pay." Available at: http://www.mscode.com/free/statutes/49/031/0025.htm, last accessed on November 16, 2011. Hazardous waste gene ration fee based on "100.00 to 999.99 tons" generated/released
category. (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA

Hazar dous Waste Regulation . July 17, 2003. p. 169.

## Appendix B (continued)

Avoided State Waste Fees and Taxes

March 16, 2012 DRAFT C

- 6 State Hazardous Waste Management State Hazardous Waste

Fees and Taxes State Non

- Hazardous Waste

Fees and Taxes

Data Source(s) Management Generation Management

Tons Managed in

Landfill Tons Managed in

Incinerator Disposal ($/ton) Incineration ($/ton) ($/ton) Disposal ($/ton) Incineration ($/ton)

Missouri 9,040 18,056 $25.50 $2.00 $5.00 $0.00 $0.00 (1) State of Missouri. Missouri Revised Statutes , "Chapter 260

- Environmental Control,"

"Section 260.475

- Fees to be Paid by Hazardous Waste Generators

-- Exceptions

-- Deposit of Moneys

-- Violations, Penalty

-- Deposit

-- Fee Requirement, Expiration." Available at: http://www.moga.mo.gov/statutes/C200

- 299/2600000475.HTM, last accessed on November 16,

2011. (2) State of Missouri. Missouri Revised Sta tutes , "Chapter 260

- Environmental Control,"

"Section 260.390

- Duties of Hazardous Waste Facility Owners and Operators

-- Tax to be Collected, Disposition

-- Duties upon Termination of Use of Facility

-- Inspection Fees, Commercial Facilities, Requirements." Available at: http://www.moga.mo.gov/statutes/C200

- 299/2600000390.HTM, last accessed on November 16, 2011. (3) State of Missouri. Missouri Revised Statutes , "Chapter 260

- Environmental Control,"

"Section 260.380

- Duties of Hazardous Waste Generators

-- F ees to be Collected, Disposition

-- Exemptions." Available at: http://www.moga.mo.gov/statutes/C200

- 299/2600000380.HTM, last
accessed on November 16, 2011. (4) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of

National Eco nomic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. July 17, 2003. p. 169.

Montana 6,434 662 $8.00 $8.00 $15.00 $0.00 $0.00 Montana Department of Environmental Quality, "Hazardous Waste Program" Web site. Available at: http://deq.mt.gov/HazWaste/default.mcpx, last accessed on November 16, 2011.

Nebraska 37,345 1,220 $22.40 $1.92 $0.00 $0.00 $0.00 U.S. Environmental Protection Agency. Economics Background Document

- Estimate of

National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

Nevada 7,549 726 $40.20 $17.75 $0.00 $0.00 $0.00 U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

New Hampshire 22 95 60 60 $0.00 $1.00 $0.00 U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

New Jersey 397,378 13,958 $0.00 $0.00 $0.00 $0.00 $0.00 (1) State of New Jersey. "Hazardous Waste Regulations, N.J.A.C. 7:26G

- 1 et seq," "Subchapter 3

- Hazardous Waste Fees, "Section 7:26G

- 3.3

- Fee Schedule for Hazardous Waste Facilities, Generators, and Transporters." Available at: http://www.state.nj.us/ dep/dshw/resource/hazreg03.pdf, last accessed on November 16, 2011. Hazardous waste generation fee based on "Equal to or greater than 150 tons of hazardous waste generated" category. (2) U.S. Environmental Protection Agency. Economics Background Documen t

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

## Appendix B (continued)

Avoided State Waste Fees and Taxes

March 16, 2012 DRAFT C

- 7 State Hazardous Waste Management State Hazardous Waste

Fees and Taxes State Non

- Hazardous Waste

Fees and Taxes

Data Source(s) Management Generation Management

Tons Managed in

Landfill Tons Managed in

Incinerator Disposal ($/ton) Incineration ($/ton) ($/ton) Disposal ($/ton) Incineration ($/ton)

New Mexico 838 1,055 $0.00 $0.00 $0.00 $0.00 $0.00 U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

New York 41,665 14,444 $27.00 $9.00 $0.00 $0.00 $0.00 (1) New York State Department of Environmental Conservation. "Hazardous Waste Assessments and Fees" Web site. Available at: http://www.dec.ny.gov/chemical/9099.html, last
accessed on November 16, 2011. (2) U.S. Army Corps of Engineers, HTRW Center of Expertise Info rmation

- TSDF. Report on Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 2006 Update, "Section 13

- State Taxes and Fees." Available at: http://www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last access ed on November 15,

2011. (3) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. July 17, 2003. p. 169.

North Carolina 26,886 26,015 $2.45 $2.45 $0.70 $0.00 $0.00 (1) North Carolina Department of Environment and Natural Resources. "Hazardous Waste Section" Web site, "Hazardous Waste 2010 Fee Increase." Available at: http://portal.ncdenr.org/web/wm/hw, last accessed on November 16, 2011. Hazardous waste generation fee based on LQG. (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

North Dakota 0 229 $0.00 $0.00 $0.00 $0.00 $0.00 (1) U.S. Army Corps of Engineers, HTRW Center of Expertise Information

- TSDF. Report on Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 2006 Update, "Section 13

- State Taxes and Fees." Available at: http://www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last accessed on November 15,

2011. (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

Ohio 63,341 38,785 $9.00 $2.00 $0.00 $0.00 $0.00 (1) State of Ohio. Ohio Revised Code , "Title [37] XXXVII

- Health

- Safety

- Morals," "Chapter

3734

- Solid and Hazardous Wastes," "Section 3734.18

- Fees

- Hazardous Waste Facility Management Fund." Available at: http://codes.ohio.gov/orc/3734.18, last accessed on
November 16, 2011. (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

## Appendix B (continued)

Avoided State Waste Fees and Taxes

March 16, 2012 DRAFT C

- 8 State Hazardous Waste Management State Hazardous Waste

Fees and Taxes State Non

- Hazardous Waste

Fees and Taxes

Data Source(s) Management Generation Management

Tons Managed in

Landfill Tons Managed in

Incinerator Disposal ($/ton) Incineration ($/ton) ($/ton) Disposal ($/ton) Incineration ($/ton)

Oklahoma 9,075 1,815 $9.00 $9.00 $0.00 $0.00 $0.00 (1) State of Oklahoma. Oklahoma Administrative Code , "Title 252

- Department of Environmental Quality," "Chapter 205

- Hazardous Waste Management," "Section 252:205

- 21

- 2

- Generator Fees." Available at: http://www.deq .state.ok.us/rules/205.pdf, last accessed on
November 16, 2011. (2) State of Oklahoma. Oklahoma Administrative Code , "Title 252

- Department of Environmental Quality," "Chapter 205

- Hazardous Waste Management," "Section 252:205

- 21

- 4

- Treatment, Storage , Off

- Site Recycling, and Disposal Facility Fees." Available at: http://www.deq.state.ok.us/rules/205.pdf, last accessed on November 16, 2011. (3) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impac t for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation. July 17, 2003. p. 169.

Oregon 48,983 4,014 $176.90 $117.94 $0.00 $0.00 $0.00 (1) State of Oregon Department of Environmental Quality. "Hazardous Waste Generator Fee

Information" Fact Sheet. Available at: http://www.deq.state.or.us/lq/pubs/factsheets/hw/HWGeneratorFee.pdf, last accessed on November 16, 2011. Hazardous waste generation fee based on LQG. (2) U.S. Environmental Protection Agency. Econom ics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

Pennsylvania 46,439 14,465 $12.00 $5.00 $0.00 $3.00 $0.00 (1) U.S. Army Corps of Engineers, HTRW Center of Expertise Information

- TSDF. Report on Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 2006 Update, "Section 13

- State Taxes and Fees." Available at: http:/ /www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last accessed on November 15,

2011. (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

Rhode Island 57 1,455 $0.00 $0.00 $0.00 $0.00 $0.00 (1) U.S. Army Corps of Engineers, HTRW Center of Expertise Information

- TSDF. Report on Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 2006 Update, "Section 13

- State Taxes and Fees." Available at: http://www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last accessed on November 15,

2011. (2) U.S. Environmental Protection Agency. Econom ics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

## Appendix B (continued)

Avoided State Waste Fees and Taxes

March 16, 2012 DRAFT C

- 9 State Hazardous Waste Management State Hazardous Waste

Fees and Taxes State Non

- Hazardous Waste

Fees and Taxes

Data Source(s) Management Generation Management

Tons Managed in

Landfill Tons Managed in

Incinerator Disposal ($/ton) Incineration ($/ton) ($/ton) Disposal ($/ton) Incineration ($/ton)

South Carolina 8,397 5,337 $34.00 $10.00 $0.00 $13.70 $10.00 (1) South Carolina Department of Health and Environmental Control, Land and Waste Management. "Laws & Regulations" Web site, "South Carolina Hazardous Waste Management Regulations R.61

- 79," "Section 264.78

- Hazardous Waste Contingency Fund Fees." Available

at: h ttp://www.scdhec.gov/environment/lwm/regs/264%2010.pdf, last accessed on November

16, 2011. (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wip es from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

South Dakota 6 262 $50.00 $50.00 $0.00 $0.00 $0.00 (1) State of South Dakota. South Dakota Codified Laws , "Title 34A

- Environmental Protection," "Chapter 34A

- 11

- Hazardous Waste Management," "Section 34A

- 11

- 25

- Disposal Fee Levied by State

-- Records." Available at: http://legis.state.sd.us/statutes/DisplayStatute.aspx?Type=Statute&Statute=34A

- 11

- 25, last
accessed on November 16, 2011. (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

Tennessee 5,015 5,175 $5.00 $2.50 $0.00 $0.00 $0.00 (1) State of Tennessee. "Rules of the Tennessee Department of Environment and Conservation, Division of Solid/Hazardous Waste Management," "Chapter 1200

- 01

- 11

- Hazardous Waste Management Regulations," "Section 1200

- 1

- 11

- .08

- Fee System for Transporters, Storers, Treaters, Disposers, and Certain Generators of Hazardous Wastes and for Certain Used Oil Facilities or Transporters." Available at: http://www.state.tn.us/sos/rules/1200/1200

- 01/1200

- 01

- 11/1200

- 01

- 11

- .08.pdf, last accessed on
November 16, 2011. (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

Texas 84,904 104,074 $30.00 $16.00 $2.00 $6.00 $3.20 Texas Natural Resource Conservation Commission. Texas Commission on Environmental Quality Rules and Regulations, "Chapter 335

- Industrial Solid Waste and Municipal Hazardous Waste," "Subchapter J

- Hazardous Waste Generati on, Facility and Disposal Fee System." Available at: http://www.tceq.state.tx.us/assets/public/legal/rules/rules/pdflib/335j.pdf, last
accessed on November 16, 2011.

Utah 80,701 6,401 $14.00 $9.00 $0.00 $0.00 $2.50 (1) State of Utah. "Hazardous Waste and Nonhazardous Solid Waste Fee and Tax Amendments," 2004 General Session." Available at: http://www.le.state.ut.us/~2004/bills/hbillint/hb0013.htm, last accessed on November 16, 2011. (2) U.S. Environmental Protection Agency. Economics Background Doc ument

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 170.

## Appendix B (continued)

Avoided State Waste Fees and Taxes

March 16, 2012 DRAFT C

- 10 State Hazardous Waste Management State Hazardous Waste

Fees and Taxes State Non

- Hazardous Waste

Fees and Taxes

Data Source(s) Management Generation Management

Tons Managed in

Landfill Tons Managed in

Incinerator Disposal ($/ton) Incineration ($/ton) ($/ton) Disposal ($/ton) Incineration ($/ton)

Vermont 364 109 $112.00 $56.00 $0.00 $6.00 $0.00 U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 170.

Virginia 7,868 9,769 $0.00 $0.00 $0.00 $0.00 $0.00 (1) U.S. Army Corps of Engineers, HTRW Center of Expertise Information

- TSDF. Report on Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 2006 Update, "Section 13

- State Taxes and Fees." Available at: http:/ /www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last accessed on November 15,

2011. (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 170.

Washington 20,175 5,607 $0.00 $0.00 $12.00 $8.03 $8.03 U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 170.

West Virginia 1,718 5,796 $35.29 $26.47 $0.00 $0.00 $0.00 U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 170.

Wisconsin 11,958 11,912 $0.15 $0.15 $12.83 $0.30 $0.00 U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 170.

Wyoming 2,044 1,517 $0.00 $0.00 $0.00 $0.00 $0.00 (1) U.S. Army Corps of Engineers, HTRW Center of Expertise Information

- TSDF. Report on Treatment, Storage & Disposal Facilities (TSDF) for Hazardous, Toxic, and Radioactive Waste, 2006 Update, "Section 13

- State Taxes and Fees." Available at: http:/ /www.environmental.usace.army.mil/TSDF/rp0s13_2.htm, last accessed on November 15,

2011. (2) U.S. Environmental Protection Agency. Economics Background Document

- Estimate of National Economic Impact for Conditional Exclusion of Solvent Industrial Wipes from RCRA Hazardous Waste Regulation . July 17, 2003. p. 169.

Tons

- Weighted Mean Fee/Tax Rate ($/ton) $25.00 $35.00 $1.18 $1.98 $1.51

### March 16, 2012 DRAFT C

- 1 

## Appendix C

Number of Facilities that Generate Solvent

- Contaminated Wipes, by Industry a

Economic

Sub

- Sector Industries (5

- or 6

-

Digit

NAICS Code) a LQGs SQGs Total Percent of All

Facilities that

Are LQGs

Reusable Wipes c Percent of All

Facilities that

Are SQGs

Reusable Wipes d Percent of All

Facilities that

Are LQGs Disposable

Wipes e Percent of All

Facilities that

Are SQGs Disposable

Wipes f Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Subtotal Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Subtotal Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Total

Printing 323110 11 1 12 5,654 492 6,146 5,665 493 6,158 0.18% 91.82% 0.02% 7.98%

323111 9 1 10 135 12 147 144 13 156 5.74% 86.26% 0.50% 7.50%

323112 5 0 5 422 37 459 427 37 464 1.04% 90.96% 0.09% 7.91%

323113 1 0 1 2,189 190 2,379 2,190 190 2,380 0.03% 91.97% 0.00% 8.00%

323114 0 0 0 3,209 279 3,488 3,209 279 3,488 0.00% 92.00% 0.00% 8.00%

323115 0 0 0 876 76 952 876 76 952 0.00% 92.00% 0.00% 8.00%

323116 0 0 0 292 25 318 292 25 318 0.00% 92.00% 0.00% 8.00%

323117 0 0 0 251 22 272 251 22 272 0.00% 92.00% 0.00% 8.00%

323118 0 0 0 95 8 103 95 8 103 0.00% 92.00% 0.00% 8.00%

323119 1 0 2 1,042 91 1,133 1,043 91 1,134 0.12% 91.88% 0.01% 7.99%

323121 0 0 0 480 42 522 480 42 522 0.00% 92.00% 0.00% 8.00%

323122 2 0 2 712 62 774 714 62 776 0.27% 91.73% 0.02% 7.98%

Publishing (printed matter) 51111 0 0 0 4,003 348 4,351 4,003 348 4,351 0.00% 92.00% 0.00% 8.00%

51112 0 0 0 3,638 316 3,954 3,638 316 3,954 0.0 0% 92.00% 0.00% 8.00%

51113 0 0 0 1,535 134 1,669 1,535 134 1,669 0.00% 92.00% 0.00% 8.00%

51114 0 0 0 855 74 929 855 74 929 0.00% 92.00% 0.00% 8.00%

51119 1 0 1 639 56 695 640 56 695 0.10% 91.90% 0.01% 7.99%

Business

services (copy shops) 561439 1 0 2 2,632 229 2,861 2,633 229 2,862 0.05% 91.95% 0.00% 8.00%

## Appendix C (continued)

Number of Facilities that Generate Solvent

- Contaminated Wipes, by Industry a



### March 16, 2012 DRAFT C

- 2 Economic

Sub

- Sector Industries (5

- or 6

-

Digit

NAICS Code) a LQGs SQGs Total Percent of All

Facilities that

Are LQGs

Reusable Wipes c Percent of All

Facilities that

Are SQGs

Reusable Wipes d Percent of All

Facilities that

Are LQGs Disposable

Wipes e Percent of All

Facilities that

Are SQGs Disposable

Wipes f Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Subtotal Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Subtotal Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Total

Chemical and

Allied

Products 211112 0 0 0 45 4 49 45 4 49 0.00% 92.00% 0.00% 8.00%

32511 1 0 2 7 1 7 8 1 9 15.58% 76.42% 1.35% 6.65%

32512 1 0 2 76 7 83 78 7 84 1.63% 90.37% 0.14% 7.86%

325131 2 0 2 11 1 12 13 1 14 14.73% 77.27% 1.28% 6.72%

325132 1 0 2 14 1 15 15 1 16 8.44% 83.56% 0.73% 7.27%

325181 1 0 1 6 1 7 7 1 7 9.22% 82.78% 0.80% 7.20%

325182 0 0 0 4 0 5 4 0 5 0.00% 92.00% 0.00% 8.00%

325188 8 1 9 78 7 84 86 7 93 8.86% 83.14% 0.77% 7.23%

325191 0 0 0 7 1 8 7 1 8 0.00% 92.00% 0.00% 8.00%

325192 1 0 1 4 0 4 4 0 5 14.57% 77.43% 1.27% 6.73%

325193 0 0 0 34 3 37 34 3 37 0.00% 92.00% 0.00% 8.00%

325199 11 1 12 89 8 97 100 9 109 10.15% 81.85% 0.88% 7.12%

325998 11 1 12 164 14 178 175 15 190 5.80% 86.20% 0.50% 7.50%

331311 0 0 0 2 0 2 2 0 2 0.00% 92.00% 0.00% 8.00%

## Appendix C (continued)

Number of Facilities that Generate Solvent

- Contaminated Wipes, by Industry a



### March 16, 2012 DRAFT C

- 3 Economic

Sub

- Sector Industries (5

- or 6

-

Digit

NAICS Code) a LQGs SQGs Total Percent of All

Facilities that

Are LQGs

Reusable Wipes c Percent of All

Facilities that

Are SQGs

Reusable Wipes d Percent of All

Facilities that

Are LQGs Disposable

Wipes e Percent of All

Facilities that

Are SQGs Disposable

Wipes f Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Subtotal Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Subtotal Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Total

Plastics and

Rubber 31332 8 1 8 20 2 22 28 2 30 25.35% 66.65% 2.20% 5.80%

315299 0 0 0 55 5 59 55 5 59 0.00% 92.00% 0.00% 8.00%

315999 0 0 0 83 7 90 83 7 90 0.00% 92.00% 0.00% 8.00%

325991 3 0 4 79 7 86 83 7 90 3.84% 88.16% 0.33% 7.67%

326113 10 1 11 89 8 97 99 9 107 9.01% 82.99% 0.78% 7.22%

326121 1 0 1 84 7 91 85 7 92 0.75% 91.25% 0.07% 7.93%

32613 8 1 9 32 3 34 40 3 43 19.09% 72.91% 1.66% 6.34%

32614 1 0 1 77 7 84 78 7 85 0.82% 91.18% 0.07% 7.93%

32615 2 0 2 89 8 97 91 8 99 2.09% 89.91% 0.18% 7.82%

32616 0 0 0 55 5 60 55 5 60 0.00% 92.00% 0.00% 8.00%

326191 1 0 2 74 6 81 75 7 82 1.68% 90.32% 0.15% 7.85%

326192 2 0 2 6 1 7 8 1 9 22.58% 69.42% 1.96% 6.04%

326199 18 3 20 991 86 1,077 1,009 89 1,097 1.62% 90.30% 0.23% 7.85%

326211 1 0 2 17 1 18 18 2 20 7.00% 85.00% 0.61% 7.39%

32622 2 0 2 34 3 37 36 3 39 5.29% 86.71% 0.46% 7.54%

326291 4 0 5 70 6 77 75 6 81 5.10% 86.90% 0.44% 7.56%

326299 8 1 8 97 8 105 104 9 114 6.69% 85.31% 0.58% 7.42%

337215 1 0 1 120 10 131 121 11 131 0.53% 91.47% 0.05% 7.95%

339113 5 0 5 271 24 294 275 24 299 1.61% 90.39% 0.14% 7.86%

339932 0 0 0 96 8 104 96 8 104 0.00% 92.00% 0.00% 8.00%

339991 1 0 1 86 8 94 87 8 95 0.73% 91.27% 0.06% 7.94%

Fabricated

Metal

Products 332812 37 3 40 337 29 367 374 33 406 9.00% 83.00 % 0.78% 7.22%

332813 19 2 20 367 32 399 386 34 419 4.44% 87.56% 0.39% 7.61%

339911 0 0 0 246 21 268 246 21 268 0.00% 92.00% 0.00% 8.00%

339912 0 0 0 20 2 21 20 2 21 0.00% 92.00% 0.00% 8.00%

339914 0 0 0 80 7 86 80 7 86 0.00% 92.00% 0.00% 8.00%

## Appendix C (continued)

Number of Facilities that Generate Solvent

- Contaminated Wipes, by Industry a



### March 16, 2012 DRAFT C

- 4 Economic

Sub

- Sector Industries (5

- or 6

-

Digit

NAICS Code) a LQGs SQGs Total Percent of All

Facilities that

Are LQGs

Reusable Wipes c Percent of All

Facilities that

Are SQGs

Reusable Wipes d Percent of All

Facilities that

Are LQGs Disposable

Wipes e Percent of All

Facilities that

Are SQGs Disposable

Wipes f Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Subtotal Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Subtotal Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Total

Industrial Machinery

and Equipment 314999 0 0 0 308 27 334 308 27 334 0.00% 92.00% 0.00% 8.00%

332323 1 0 2 367 32 399 368 32 400 0.34% 91.66% 0.03% 7.97%

33241 1 0 1 43 4 47 44 4 48 1.45% 90.55% 0.13% 7.87%

332991 0 0 0 26 2 28 26 2 28 0.00% 92.00% 0.00% 8.00%

333111 3 0 3 165 14 179 167 15 182 1.52% 90.48% 0.13% 7.87%

33312 3 0 4 110 10 119 113 10 123 2.81% 89.19% 0.24% 7.76%

33322 0 0 0 74 6 80 74 6 80 0.00% 92.00% 0.00% 8.00%

333295 2 0 2 29 3 32 31 3 34 6.10% 85.90% 0.53% 7.47%

333298 1 0 1 180 16 196 181 16 196 0.35% 91.65% 0.03% 7.97%

333319 1 0 1 190 17 206 191 17 207 0.33% 91.67% 0.03% 7.97%

333414 0 0 0 59 5 64 59 5 64 0.00% 92.00% 0.00% 8.00%

333511 1 0 1 282 25 307 283 25 307 0.22% 91.78% 0.02% 7.98%

333512 1 0 1 81 7 88 81 7 88 0.78% 91.22% 0.07% 7.93%

333513 0 0 0 41 4 45 41 4 45 0.00% 92.00% 0.00% 8.00%

333514 0 0 0 442 38 480 442 38 480 0.00% 92.00% 0.00% 8.00%

333515 0 0 0 215 19 234 215 19 234 0.00% 92.00% 0.00% 8.00%

333518 0 0 0 54 5 58 54 5 58 0.00% 92.00% 0.00% 8.00%

333911 3 0 3 68 6 74 71 6 77 3.59% 88.41% 0.31% 7.69%

333923 3 0 4 39 3 42 42 4 46 7.48% 84.52% 0.65% 7.35%

333999 2 0 2 232 20 252 234 20 254 0.81% 91.19% 0.07% 7.93%

33651 1 0 1 30 3 33 31 3 34 2.04% 89.96% 0.18% 7.82%

## Appendix C (continued)

Number of Facilities that Generate Solvent

- Contaminated Wipes, by Industry a



### March 16, 2012 DRAFT C

- 5 Economic

Sub

- Sector Industries (5

- or 6

-

Digit

NAICS Code) a LQGs SQGs Total Percent of All

Facilities that

Are LQGs

Reusable Wipes c Percent of All

Facilities that

Are SQGs

Reusable Wipes d Percent of All

Facilities that

Are LQGs Disposable

Wipes e Percent of All

Facilities that

Are SQGs Disposable

Wipes f Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Subtotal Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Subtotal Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Total

Furniture and

Fixtures 337110 13 1 14 1,383 120 1,503 1,396 121 1,517 0.86% 91.14% 0.08% 7.92%

337121 0 0 0 206 18 224 206 18 224 0.00% 92.00% 0.00% 8.00%

337122 1 0 2 502 44 546 503 44 547 0.25% 91.75% 0.02% 7.98%

337124 0 0 0 49 4 54 49 4 54 0.00% 92.00% 0.00% 8.00%

337127 0 0 0 96 8 105 96 8 105 0.00% 92.00% 0.00% 8.00%

337211 2 0 2 68 6 74 70 6 76 2.73% 89.27% 0.24% 7.76%

337212 1 0 1 225 20 245 226 20 246 0.28% 91.72% 0.02% 7.98%

337215 1 0 1 120 10 131 121 11 131 0.53% 91.47% 0.05% 7.95%

Auto Dealers (retail trade) 44111 0 0 0 3,425 298 3,723 3,425 298 3,723 0.00% 92.00% 0.00% 8.00%

44112 1 0 1 3,775 328 4,103 3,776 328 4,104 0.0 2% 91.98% 0.00% 8.00%

Military Bases 92812 0 0 0 39 3 43 39 3 43 0.00% 92.00% 0.00% 8.00%

Electronics

and Computers 334411 2 0 2 8 1 9 11 1 11 18.07% 73.93% 1.57% 6.43%

334412 9 1 10 92 8 100 101 9 110 8.17% 83.83% 0.71% 7.29%

334413 38 3 41 98 9 106 136 12 148 25.69% 66.31% 2.23% 5.77%

## Appendix C (continued)

Number of Facilities that Generate Solvent

- Contaminated Wipes, by Industry a



### March 16, 2012 DRAFT C

- 6 Economic

Sub

- Sector Industries (5

- or 6

-

Digit

NAICS Code) a LQGs SQGs Total Percent of All

Facilities that

Are LQGs

Reusable Wipes c Percent of All

Facilities that

Are SQGs

Reusable Wipes d Percent of All

Facilities that

Are LQGs Disposable

Wipes e Percent of All

Facilities that

Are SQGs Disposable

Wipes f Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Subtotal Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Subtotal Use Primarily

Reusable

Wipes Use Primarily Disposable

Wipes Total

Transportation

Equipment 332912 0 0 0 54 5 58 54 5 58 0.00% 92.00% 0.00% 8.00%

336111 7 1 8 20 2 22 27 2 29 23.40% 68.60% 2.04% 5.96%

336112 5 0 5 7 1 8 12 1 13 36.34% 55.66% 3.16% 4.84%

336211 12 1 14 106 9 116 119 10 129 9.62% 82.38% 0.84% 7.16%

336312 3 0 3 123 11 134 126 11 137 2.02% 89.98% 0.18% 7.82%

33633 3 0 3 33 3 36 36 3 39 7.14% 84.86% 0.62% 7.38%

33634 0 0 0 33 3 36 33 3 36 0.00% 92.00% 0.00% 8.00%

336399 9 1 10 196 17 213 205 18 223 4.03% 87.97% 0.35% 7.65%

336411 22 2 24 22 2 24 44 4 48 46.48% 45.52% 4.04% 3.96%

336412 13 1 14 41 4 44 54 5 59 22.33% 69.67% 1.94% 6.06%

336414 10 1 11 0 0 0 10 1 11 92.00% 0.00% 8.00% 0.00%

336415 3 0 3 1 0 1 4 0 4 66.92% 25.08% 5.82% 2.18%

336419 0 0 0 7 1 8 7 1 8 0.00% 92.00% 0.00% 8.00%

336612 12 1 13 148 13 160 159 14 173 6.78% 85.22% 0.59% 7.41%

336992 1 0 1 8 1 9 9 1 9 7.29% 84.71% 0.63% 7.37%

48839 0 0 0 102 9 111 102 9 111 0.00% 92.00% 0.00% 8.00%

54171 8 1 8 2,128 185 2,313 2,136 186 2,321 0.33% 91.67% 0.03% 7.97%

81149 0 0 0 1,439 125 1,564 1,439 125 1,564 0.00% 92.00% 0.00% 8.00%

Auto Repair

and

Maintenance 811111 1 0 1 11,254 979 12,233 11,255 979 12,233 0.01% 91.99% 0.00% 8.00%

811112 0 0 0 463 40 504 463 40 504 0.00 % 92.00% 0.00% 8.00%

Total 397 35 432 62,081 5,398 67,479 62,478 5,434 67,911 0.58% 91.41% 0.05% 7.95%

a Estimation of number of LQGs and SQGs that generate solvent

- contaminated reusabl e and disposable wipes is discussed in Chapter 2.

b Appendix A describes each of the NAICS codes in the exhibit.

c [Percent of Total Number of Facilities that Are LQGs and Use Primarily Reusable Wipes] = [Number of LQGs that Use Primarily R eusable Wipes] / [Total Number of LQGs and SQGs].

d [Percent of Total Number of Facilities that Are SQGs and Use Primarily Reusable Wipes] = [Number of SQGs that Use Primarily R eusable Wipes] / [Total Number of LQGs and SQGs].

e [Percent of Total Number of Facilities that Are LQGs and Use Primarily Disposable Wipes] = [Number of LQGs that Use Primarily Disposable Wipes] / [Total Number of L QGs and SQGs].

f [Percent of Total Number of Facilities that Are SQGs and Use Primarily Disposable Wipes] = [Number of SQGs that Use Primarily Disposable Wipes] / [Total Number of LQGs and SQGs].